New Restrictions on Lead in PVC Articles Proposed by EU

SGS, the world’s leading testing, inspection and certification company, is advising stakeholders that the European Union (EU) has signalled its intention to expand the scope of its lead restriction under entry 63 to Annex XVII of Regulation (EC) 1907/2006 ‘Registration, Evaluation, Authorization and Restriction of Chemicals’ (REACH).

Circulated by the World Trade Organization (WTO) on June 8, 2022, the draft regulation will restrict lead and its compounds in PVC polymers and copolymers.

There are several derogations in the proposed regulations, including:

  • Certain PVC articles containing recovered rigid PVC permitted to be used for 10 years after the date of entry into force of the regulation, but subject to less than 1.5% lead in the recovered rigid PVC, and less than 0.1% lead for a layer of newly produced PVC or other material that covers the recovered rigid PVC. These PVC articles containing recovered rigid PVC are profiles and sheets for 1) specified applications in buildings and civil engineering works, 2) decks and terraces, and 3) specified interior building applications, as well as certain multi-layer pipes and fittings
  • Suppliers of PVC articles containing recovered rigid PVC with 0.1% or more of lead directed to provide the statement ‘Contains lead’ on the article – this statement can be placed on the article packaging if it is not possible on the article
  • Suppliers of PVC articles containing recovered rigid PVC required to provide documentation to national enforcement authorities, if requested, to substantiate the claims on the recovered origin of the PVC in those articles. Substantiation of such claims may include certificates issued by schemes to demonstrate traceability and recycled content, such as EN 15343:2007 ‘Plastics – Recycled Plastics – Plastics Recycling Traceability and Assessment of Conformity and Recycled Content’, or equivalent recognized standards. Claims made on the recovered origin of the PVC in imported articles must be accompanied by a certificate that provides equivalent proof of traceability and recycled content, issued by an independent third party

The following items are also exempted:

  • PVC-silica separators in lead-acid batteries, for 10 years after the date of entry into force
  • ‘Jewelry articles’ and ‘articles supplied to the general public that can be mouthed by children’ (paragraph 1, in accordance with paragraphs 2 to 5 & paragraph 7, in accordance with paragraphs 8 and 10) under entry 63 to Annex XVII of REACH
  • Articles within the scope of four pieces of legislation:
    1. Regulation (EC) 1935/2004 ‘Food contact materials and articles
    2. Directive 2011/65/EC ‘Electrical and electronic equipment (RoHS recast)’
    3. Directive 94/62/EC ‘Packaging and packaging waste’
    4. Directive 2009/48/EC ‘Toy safety’

For more information, read SGS’s original SafeGuardS 077/22.

The WTO document states the draft regulation will be adopted in Q4 of 2022. It will then be brought into force 20 days after publication in the Official Journal of the EU and brought into effect two years later.

SGS Consumer Product Services

SGS is committed to providing information about development in regulations for consumer products as complimentary services. Through a global network of laboratories, SGS provides a wide range of services including physical/mechanical testing, analytical testing and consultancy work for technical and non-technical parameters applicable to a comprehensive range of consumer products. In the end, it’s only trusted because it’s tested. Learn more about SGS’s Consumer Product Services.

SGS SafeGuardS keep you up to date with the latest news and developments in the consumer goods industry. Read the full EU Proposes to Restrict Lead in Articles Containing PVC Under REACH SafeGuardS.

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For further information contact:

Dr. HingWo Tsang

Global Information and Innovation Manager

Tel: (+852) 2774 7420



LinkedIn: sgs-consumer-goods-&-retail

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