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Are you involved in the manufacture, import or recycling of PVC or articles containing PVC?
03/05/2017 11:54:54

Are you involved in the manufacture, import or recycling of PVC or articles containing PVC?
Source: HSA
If so,the following proposal by ECHA for an EU ban on lead compounds as PVC stabilisers may affect you.Lead released during the disposal phase of PVC accounts for approximately 95% of emissions.

While the European PVC industry has already initiated the phase-out of lead compounds as PVC stabilisers, imported PVC products may still contain lead compounds and the subsequent recycling of these products may cause difficulties for the recycling industry. The public consultation is now open and comments are welcomed on the following questions by 1 June 2017.

Question-1: How much lower could the proposed 1% limit in recycled PVC be without hindering the recycling process (e.g. could it be lower for some types of products)? What is the current lead concentration in PVC articles made from recyclates? Is it necessary to add supplementary lead-based stabilisers during PVC recycling?

Question-2: If PVC waste is exported outside the EU for recycling, or for other reasons what are the quantities and is there an increasing trend? Please also specify the reason for export (if known).

Question-3: Please provide any available data on the market share of the lead-stabilised PVC articles imported into the EU as well as any other relevant information (e.g. number of importers, size of companies, market trends etc.). If you are an importer we would be interested in the quantity of PVC you import and if it contains lead as a stabiliser (this can be done confidentially).

Question-4: Please provide any additional information concerning possible socio-economic impacts of the proposed restriction. Such information might include, for example, figures on costs or cost savings as well as impacts on employment in any sector potentially impacted (e.g. lead compounds manufacturers, producers of alternatives, PVC convertors etc.). In particular impacts on SMEs (e.g. investment and effort needed to substitute lead-based stabilisers) would be of interest.

Question-5: Are there any PVC articles stabilised with lead compounds, and placed on the EU market, other that those identified in the proposal? Please indicate (i) whether these are produced by soft or rigid PVC (ii) the range of lead concentrations in these PVC applications.

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