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The EU has informed the WTO of its intention to amend the restriction of lead falling under entry 63 to Annex XVII of REACH. Upon publication in the Official Journal, the provisions will be implemented in phases starting two years after the date of entry into force.

SAFEGUARDS | Consumer Products NO. 104/19

PVC pipes stacked in construction site

On July 12, 2019, the World Trade Organization (WTO) circulated a proposal from the European Union (EU) announcing its intention to expand the scope of lead restrictions falling under entry 63 to Annex XVII of REACH. The draft regulation and Annex, notified under G/TBT/N/EU/668, contain the following:

  • Prohibiting the use of lead in articles manufactured from polymers or copolymers of vinyl chloride (PVC)
  • Prohibiting the placing on the market of articles containing at least 0.1% lead if these are manufactured from polymers or copolymers of PVC
  • Providing a 15-year exemption for certain rigid articles containing no more than 2% lead in recovered PVC materials – the lead concentration will be strengthened to 0.1% in the layer that prevents leaching and formation of lead containing dusts during article service covering the recovered PVC in these applications
  • Providing a 15-year exemption for certain flexible articles containing no more than 1% lead in recovered flexible (soft) PVC materials – the lead concentration will be strengthened to 0.1% in other materials that prevent leaching and formation of lead containing dusts during article service used with recovered PVC in these applications
  • Requiring suppliers of rigid and flexible articles containing recovered PVC materials to apply a marking with the phrase ‘Contains recovered PVC’ on the packaging before these articles are placed on the market
  • Providing a 10-year exemption for PVC-silica separators in lead acid-batteries
  • Requiring suppliers of rigid and flexible PVC articles to submit documentary evidence (EN 15343 or similar standards) on the recovered origin of PVC in these articles when requested
  • Exempting the following articles - food contact materials and articles (Regulation (EC) 1935/2004), electrical and electronic equipment (EEE, Directive 2011/65/EU), packaging (Directive 94/62/EC) and toys (Directive 2009/48/EC)
  • Exempting jewelry articles and articles supplied to the general public that are described in the preceding paragraphs under entry 63 to Annex XVII of REACH

According to the WTO document, the draft regulation is proposed to be adopted in Q3 of 2019. The proposed date of entry into force is 20 days after publication in the Official Journal of the EU (OJEU) and the provisions would be implemented in phases starting two years after the date of entry into force.

Highlights on the general prohibition/restriction of lead-containing PVC or PVC copolymer articles are summarized in Table 1.

WTO Committee on Technical Barriers to Trade, G/TBT/N/EU/668, July 12, 2019
Draft Regulation to Amend Entry 63 to Annex XVII of REACH
Substance Scope Requirement Effective Date 
Lead and its compounds (as lead) Use in PVC or PVC copolymer articles Prohibited 2 years after date of entry into force
(possibly late 2021) 
Placing on the market for PVC or PVC copolymer articles  < 0.1% 
Table 1

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