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EU Opinion Collection: RoHS Special Exemption for Lead and Cadmium in PVC

Time：

2023-07-08

The European Commission solicited opinions on the exemption proposal for the use of cadmium and lead in polyvinyl chloride (PVC) under Annex IV of the RoSH Directive.

Recently, the European Commission is soliciting opinions on the exemption proposal for the use of cadmium and lead in polyvinyl chloride (PVC) under Annex IV of the RoSH Directive. This exemption proposal applies to the use of recycled polyvinyl chloride (PVC) as a framework material for electronic and electrical equipment. The consultation period is from June 27th to July 25th.

Background

On December 14, 2015, the committee received a new exemption application (application number B-2016) for the use of cadmium and lead in the recycling of electric doors and windows containing polyvinyl chloride (PVC). This exemption applies to Class 11 electronic and electrical equipment listed in Annex I of the RoSH Directive. In order to evaluate the exemption application, the committee conducted necessary technical and scientific evaluations, including an 8-week consultation with the public and stakeholders, during which a total of 18 proposals were received. Subsequently, the committee conducted relevant consultations at the RoHS member country expert group meetings on September 22, 2017 and October 21, 2019.

According to the final report of the aforementioned 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 there are lead-free and cadmium free native PVC available in the market, the energy and natural resources required for recycling PVC (such as water, oil, and natural salt) are less than the use of new PVC. Therefore, it complies with Article 5 (1) (a) of the RoHS Directive: the total negative environmental impact, health impact, and consumer safety impact that may arise through substitution may exceed the overall environmental impact, health impact, and consumer safety benefits it generates. Therefore, the recycling and use of PVC containing lead and cadmium is related to socio-economic benefits and helps to reduce carbon emissions and promote a circular economy.

According to the RoHS directive, the maximum limit concentration for lead is 0.1% by weight, and the maximum limit concentration for cadmium is 0.01% by weight. However, according to the exemption proposal, the lead content in hard PVC materials recycled for use in electronic and electrical equipment frames does not exceed 1.5% by weight, and the cadmium content does not exceed 0.1% by weight. The exemption period is May 28, 2028. At the same time, the proposal also stipulates that from May 28, 2026, hard 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 Annex XVII, item 63, items 18 (a) to 18 (d) of the REACH Regulation (EC) No 1907/2006). For suppliers of PVC products containing recycled hard PVC, if the lead concentration in the PVC material is equal to or exceeds 0.1% of the product weight, they should indicate "lead content ≥ 0.1%" on the product or packaging, and submit documentary evidence to national law enforcement agencies to prove the source of PVC recycling in these products.