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The EU's new RoHS exemption directive for cadmium and lead in polyvinyl chloride (PVC) came into effect on January 30th!

Time：

2024-02-21

The European Commission has issued Amendment Directive (EU) 2024/232 to RoHS Directive 2011/65/EU, adding entry 46 to Annex III of Directive 2011/65/EU, granting new exemptions for cadmium and lead in plastic frame materials for electronic and electrical doors and windows containing recycled rigid polyvinyl chloride (PVC), effective on January 30, 2024.

The European Commission issued Amendment Directive (EU) 2024/232 to RoHS Directive 2011/65/EU on January 10, 2024, adding entry 46 to Annex III of Directive 2011/65/EU, granting new exemptions for cadmium and lead in plastic frame materials for electronic and electrical doors and windows containing recycled rigid polyvinyl chloride (PVC). The exemption directive will take effect on January 30, 2024, and is valid until May 28, 2028. In addition, the scope of this exemption is consistent with the relevant provisions on the recovery of lead from PVC in Annex XVII, Article 63 of the EU REACH regulation. “

Cadmium and lead are restricted substances listed in Annex II of RoHS Directive 2011/65/EU. In homogeneous materials, the maximum concentration of lead is 0.1% by weight, and the maximum concentration of cadmium is 0.01% by weight.

Cadmium and lead are used for recycling PVC door and window frame materials, and for polymer stabilization of PVC frame materials. Although there is native PVC on the market that does not contain cadmium and lead, the use of recycled PVC requires less energy and natural resources (such as water, oil, and natural salts) than the use of native PVC. The negative impact of using native PVC on the environment, health, and consumer safety may exceed its overall benefits for the environment, health, and consumer safety. Therefore, this exemption complies with one of the relevant conditions stipulated in Article 5 (1) (a) of RoHS Directive 2011/65/EU.

Directive 2011/65/EU Annex III added new entry 46

Item Number

Content

Electronic and electrical doors and windows contain cadmium and lead in the framework material of a mixture produced from polyvinyl chloride waste (hereinafter referred to as "recycled hard PVC"). The concentration of cadmium in the recycled hard PVC material does not exceed 0.1% (by weight) and the concentration of lead does not exceed 1.5% (by weight).
Starting from May 28, 2026, hard PVC recovered from electronic and electrical doors and windows can only be used for the production of new items under the category specified in Article 63, points 18 (a) to (d) of Annex XVI to the EU REACH Regulation.

Suppliers of PVC products containing recycled hard PVC with a lead concentration greater than or equal to 0.1% of the weight of the PVC material should ensure that these products are clearly, clearly, and indelibly labeled with a "Contains ≥ 01% lead" statement before being put on the market. If the nature of the item cannot be labeled, it should be labeled on the packaging of the item.

Suppliers of PVC items containing recycled hard PVC shall submit written evidence to member state law enforcement authorities upon request to confirm the declaration of the source of the recycled PVC in these items. A certificate issued by a program that provides traceability and proof of recycled ingredients, such as a certificate developed according to EN15343:2007 or equivalent recognized standards, can be used to confirm such declarations for PVC products produced in the European Union. The declaration regarding the source of PVC recycling in imported goods should be accompanied by a certificate issued by an independent third party, which can provide equivalent proof of traceability and recycled ingredients.

Scope and Deadline

Applicable to RoHS Directive Annex I, Class 11, valid until May 28, 2028.

RoHS (2011/65/EU) is a mandatory standard established by EU legislation, and its full name is the Restriction of Hazardous Substances (Restriction of Hazardous Substances). On January 27, 2003, the European Council passed the first version of RoHS Directive: 2002/95/EC; On July 1, 2011, the European Union released a new version of the RoHS Directive: 2011/65/EU, which came into effect on July 21, 2011, replacing the previous version 2002/95/EC. Mainly used to standardize the materials and process standards of electronic and electrical products, making them more conducive to human health and environmental protection. The substances prohibited by RoHS are lead (Pb), mercury (Hg), cadmium (Cd), hexavalent chromium (CrVI), polybrominated biphenyls (PBB), polybrominated diphenyl ethers (PBDE), and four different phthalates (DEHP, BBP, BBP, DIBP).

Applicable products and regions -27 member states of the European Union: United Kingdom (withdrawn from the EU in 2020), France, Germany, Italy, Netherlands, Belgium, Luxembourg, Denmark, Ireland, Greece, Spain, Portugal, Austria, Sweden, Finland, Cyprus, Hungary, Czech Republic, Estonia, Latvia, Lithuania, Malta, Poland, Slovakia, Slovenia, Bulgaria, Romania. The RoHS directive covers a wide range of products, almost covering all electronic, electrical, medical, communication, toy, security information and other products. It not only includes complete machine products, but also the components, raw materials, and packaging used in the production of complete machines, which is related to the entire production chain. Product scope: 1. Large household appliances 2. Small household appliances 3. Information technology and telecommunications equipment 4. Consumer equipment 5. Lighting equipment 6. Electric tools 7. Toys, entertainment and sports equipment 8. Medical equipment 9. Monitoring and control equipment 10. Automatic vending equipment 11. Other electronic and electrical equipment not covered by the above categories.