Q&A

How does the EU regulate products which might contain banned/restricted substances?

REACH Regulation regulates chemical substances placed on the market in the European Union, including manufacturing and import. Industry must comply with various regulatory measures including Authorisation and Restriction, and the Member States are in the position of enforcing the regulation. Enforcement activities include the control of goods which do not comply with REACH Regulation (e.g. import of goods containing restricted chemicals).

Due to the complexity of enforcement, European Chemicals Agency (ECHA) set up the Enforcement Forum which is a network of authorities responsible for the enforcement of various regulations including REACH and CLP. The role of the Forum is to harmonise and strengthen the national enforcement at the EU level by sharing experiences and expertise among the Member States as well as with relevant stakeholders. Some Member States publish reports on their own enforcement activities.

What are legacy additives, are they unique to PVC, and do they impact recycling?

‘Legacy additives’ are additives which are no longer use in PVC produced today in the EU, but can still be found in old PVC products being recycled. Legacy additives are a common challenge for many materials, including PVC and other plastics. The presence of these substances and the fact that many historical products are composed of different materials can create challenges. However, these challenges are not unsurmountable:

  • One effective way to ensure that PVC containing legacy additives can be recycled whilst safeguarding human health and the environment is to set maximum concentration values for legacy additives in PVC products containing recycled PVC.
  • Other solutions are being developed: There are major research programmes by the industry on recycling technologies enabling the extraction of legacy additives. These programmes are still at pilot stage. Innovation takes a decade to be fully mature, which is why legislation needs to allow time for these innovations to be ready.

Due to the long shelf life of PVC products of up to 100 years or more, waste will be generated in the coming decades containing substances that were previously considered safe to use but are now unwanted. The PVC industry is working with the authorities in Europe to ensure that the resources in PVC already produced are utilised without compromising a high level of protection for health and the environment.[1]

[1] VinylPlus, Is PVC a problematic plastic?: From production to use to waste management: everything you need to know about PVC. V-is-PVC-plastic_16-09.pdf

Are organotin stabilisers safe to use in PVC?

Yes, when compliant with regulations, organotin stabilisers are safe for use. Organotin compounds account for only 6%, but still play an important role in certain applications as they ensure transparency and work even under harsh processing conditions. As mentioned above, the use of additives in PVC and other plastics is regulated by REACH, which means that manufacturers must prove that the substances are safe before they are placed on the market. This also applies to stabilisers, which are always used to process the PVC plastic and to achieve the desired properties of the product. Stabilisers make up a very small amount of the product’s weight and are tightly bound in the polymer matrix, so migration is minimal. Some organotin compounds are restricted, while others may continue to be used in critical applications such as food contact materials, medicine blister packs and medical devices. There is still significant use of organotin stabilisers outside the EU, including in North America, where the use of such products is based on risk assessments demonstrating safe use and regulatory approvals, such as the National Sanitation Foundation (NSF).

Are lead and cadmium still used outside Europe?

When it comes to lead, Europe and North America have been leading the phase-out, but the rest of the world is well on its way. The conversion rate from lead to calcium-based stabilisers has moved from around 40% to 80% since 2017. This is partly due to bans on their use in drinking water pipes in India and China, as well as increased global exchange of knowledge and technology in the PVC field.

Cadmium is only used in very limited quantities in PVC worldwide, making it difficult to obtain accurate tonnage data.