SAFEGUARDS | Consumer Products NO. 046/17

SafeGuardS PVC pipes stacked in construction site

The ECHA is seeking public opinion on its proposal to restrict lead compounds in articles containing PVC. If eventually approved, the restriction will become effective two years from the date of entry into force.

The European Chemicals Agency (ECHA) has recently initiated a 6-month public consultation on its proposal [1] to restrict lead compounds in articles containing polyvinyl chloride (PVC). This consultation started on March 22, 2017, and will end on September 22, 2017. The rapporteurs for the ECHA Committees for Risk Assessment (RAC) and Socio-economic Analysis (SEAC) welcome any comments by the first deadline of June 1, 2017, to assist their early discussions on the proposal.

According to the proposal, the restriction would provide a new entry to Annex XVII of REACH and aims to restrict lead compounds as PVC stabilizers in articles. These articles are commonly manufactured from rigid PVC, with 70-80% of PVC used in the building and construction industries in the EU. 

The proposal also contains a number of exemptions, including:

  • A number of specific types of article containing recycled PVC for 15 years from the date of entry into force, provided that these articles contain no more than 1% lead. These articles are to be marked with ‘Contains recycled PVC’ or the same pictogram [2] as for cadmium in entry 23 to Annex XVII of REACH

  • Articles that can be placed in the mouth (paragraph 7 [3], entry 63 to Annex XVII of REACH)

  • Electrical products (Directive 2011/65/EU, RoHS Recast).

  • Food contact materials and articles (Regulations (EC) 1935/2004 and (EU) 10/2011).

  • Packaging and packaging waste (Directive 94/62/EC)

  • PVC-silica separators in lead acid batteries for 10 years

  • Toys (Directive 2009/48/EC)

The restriction on lead will become effective 24 months from the date of entry into force upon acceptance by the European Commission (EC) and publication in the Official Journal of the European Union (OJEU).

Highlights of the proposal are summarized in Table 1.

Proposal for a restriction relating to lead compounds-PVC
Annex XV Restriction Report, December 16, 2016
Substance Scope Requirement Effective Date
Lead compounds
(Expressed as lead)
PVC-containing articles  ≤ 0.1% 2 Years from date of entry into force

SGS will follow up and inform interested parties as developments on REACH regulation occur. Our expertise combined with consultancy services and experience in consumer product supply chains provides a central point of contact for global solutions. If you would like to learn more about how SGS can support your REACH compliance activities please visit


For enquiries, please contact:

Hingwo Tsang
Global Hardlines Information and Innovation Manager
t: +852 2774 7420

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