EU Approves RoHS exemptions for Cadmium and Lead in PVC Applications
Published: Author: Visits: 144

On January 10, 2024, the EU Commission approved the exemption for cadmium and lead in plastic profiles in electrical and electronic windows and doors containing recovered rigid polyvinyl chloride (PVC) in its Commission Delegated Directive (EU) 2024/232 and a new entry 46 is added to Annex III to Directive 2011/65/EU (RoHS).

Details are as follows:

EntryContentScope and validity period
46

Cadmium and lead in plastic profiles containing mixtures produced from polyvinyl chloride waste (hereinafter referred to as “recovered rigid PVC”), used for electrical and electronic windows and doors, where the concentration in the recovered rigid PVC material does not exceed 0,1 % cadmium by weight and 1,5 % lead by weight.

From 28 May 2026, rigid PVC recovered from electrical and electronic windows and doors shall only be used for the production of new articles under the categories specified in entry 63, points 18(a) to (d) of Annex XVII to Regulation (EC) No 1907/2006.

Suppliers of PVC articles containing recovered rigid PVC with a concentration of lead equal to or greater than 0,1 % by weight of the PVC material shall ensure, before placing those articles on the market, that they are visibly, legibly and indelibly marked with the statement: Contains 0,1 % lead. Where the marking cannot be provided on the article due to the nature of the article, it shall be on the packaging of the article.

Suppliers of PVC articles containing recovered rigid PVC shall submit to national enforcement authorities upon request documentary evidence to substantiate the claims on the recovered origin of the PVC in those articles. Certificates issued by schemes to provide proof of traceability and recycled content, such as those developed according to EN 15343:2007 or equivalent recognised standards, may be used to substantiate such claims for PVC articles produced in the Union. Claims made on the recovered origin of the PVC in imported articles shall be accompanied by a certificate that provides equivalent proof of traceability and recycled content, issued by an independent third party.

Applies to category 11 and expires on 28 May 2028.

The provisions took effect on January 30 2024, and will be applicable across all EU member states from 1 August, 2024.

Background

On 14 December 2015, the Commission received an application made in accordance with Article 5(3) of Directive 2011/65/EU (RoHS) for granting an exemption for cadmium and lead in electrical and electronic windows and doors containing recovered polyvinyl chloride (PVC) (‘the requested exemption’). Review results show that while lead- and cadmium-free virgin PVC is available on the market, the use of recovered PVC requires lower amounts of energy and natural resources (such as water, petroleum and natural salt) than the amounts that would be otherwise needed for the use of virgin PVC. Therefore, the total negative environmental, health and consumer safety impacts caused by substitution would likely outweigh the total environmental, health and consumer safety benefits thereof. Besides, the exemption does not weaken the environmental and health protection afforded by the REACH Regulation. For these reasons, the EU Commission approved the exemptions.

About RoHS

RoHS is short for "The Directive on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment”. The first version of RoHS Directive (2002/95/EC) was passed by the European Parliament on 27 January 2003; the European Union published the new version of RoHS Directive, RoHS 2 Directive (2011/65/EU), on 1 July 2011 and the new directive became effective on 21 July 2011, taking the place of the previous version.

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