RoHS exemption for lead and cadmium in PVC
The European Commission is currently soliciting comments on an exemption proposal for cadmium and lead in polyvinyl chloride (PVC) under Appendix IV of the RoSH Directive. The proposed exemption applies to the use of recycled polyvinyl chloride (PVC) as a framing material for electronic and electrical equipment. The comment period is from June 27 to Ju
The European Commission is currently soliciting comments on an exemption proposal for cadmium and lead in polyvinyl chloride (PVC) under Appendix IV of the RoSH Directive. The proposed exemption applies to the use of recycled polyvinyl chloride (PVC) as a framing material for electronic and electrical equipment. The comment period is from June 27 to July 25.
Background:
On December 14, 2015, the Commission received an application for a new exemption for the use of cadmium and lead in the recycling of electric doors and Windows containing polyvinyl chloride (PVC) (Application No. B-2016). This exemption applies to Category 11 electrical and electronic equipment listed in Annex I to the RoSH Directive. In order to evaluate the exemption application, the Commission conducted the necessary technical and scientific assessments, including an eight-week public and stakeholder consultation on the application, during which a total of 18 proposals were received. Subsequently, the Committee consulted at the meetings of the Expert Group of RoHS Member States on 22 September 2017 and 21 October 2019.
According to the final report of the above technical and scientific evaluation, the use of cadmium and lead in the frame materials of PVC doors and Windows is to improve the stability of the polymer. Although lead-free and cadmium-free raw PVC is available on the market, recycling PVC requires less energy and natural resources (such as water, oil and natural salt, etc.) than using new PVC, thus complying with Article 5 (1) (a) of the RoHS Directive: The overall negative environmental impact, health impact and consumer safety impact that may result from substitution may outweigh the overall environmental impact, health impact and consumer safety benefit. Recycling PVC containing lead and cadmium is therefore associated with socio-economic benefits and contributes to reducing carbon emissions and promoting a circular economy.
According to the RoHS Directive, the limit concentration of lead is up to 0.1% by weight and the limit concentration of cadmium is up to 0.01% by weight. However, according to the exemption proposal, the lead content in rigid PVC materials recycled for frame materials of electronic and electrical equipment will not exceed 1.5 percent by weight and the cadmium content will not exceed 0.1 percent by weight, and the exemption period will be May 28, 2028. At the same time, the proposal also stipulates that from 28 May 2026, rigid PVC recovered from electronic and electrical doors and Windows can only be used for the production of new products in accordance with the categories specified in Article 18 (a) to 18 (d) of Annex XVII, Item 63, of the REACH Regulation (EC) No 1907/2006. For suppliers of PVC products containing recycled rigid PVC, if the lead concentration in the PVC material is equal to or more than 0.1% of the weight of the product, the product or packaging should be marked “ Lead content ≥ 0.1% & throughout; And submit documentary evidence to national law enforcement agencies to prove the source of the recycled PVC in these products.
Consultation
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