**Update: MEPs voted to reject the Commission’s proposal to allow higher levels of lead in recycled PVC on Wednesday 12th February, with 394 votes for, 241 votes against and 13 abstentions**
Some PVC plastic waste – for example from old PVC window frames – contains lead, a well-known health hazard which is no longer used in new PVC produced in the EU. This has led to discussions on whether it should be possible to recycle lead-contaminated PVC waste into new PVC products. However, given that these new products will still be contaminated with lead, this recycling would only be possible if a planned EU restriction on lead in PVC was weakened to allow recycled products to be more contaminated than new ones.
This is what the European Commission proposed on 19 November 2019, but the Parliament’s Environment committee has already said ‘No’. On Wednesday 12th February the whole European Parliament will vote on this issue – in CHEM Trust’s view it should back the Environment committee and object to weaker safety standards for recycled PVC, and vote for a clean circular economy.
The problem with lead
As CHEM Trust examined in our recent ’No Brainer’ report, Lead is well known for its neurodevelopmental impacts:
“Lead has been well known to cause intellectual disabilities for many years, with no known safe blood concentration. Even blood lead concentrations as low as 5 µg/dl, once thought to be a “safe level”, may result in decreased intelligence in children, behavioural difficulties and learning problems. Lead exposure is believed to be responsible for the loss of more than 22 million IQ points in young children in the US.
New evidence also shows associations between blood lead levels and ADHD, inattention and hyperactivity. Although mostly eliminated from petrol in the developed world, lead can still be present in paint in old houses and old water pipes. These ongoing low level exposures continue to damage the future of millions of children who may never reach their full intellectual potential.”
Phase out is required and feasible
There is no safe level of lead, which means that lead emissions should be phased out as far as possible. Lead has already been banned from paints, petrol, electronics and certain consumer products. The PVC industry has also started to act, and phased out the use of lead in PVC in 2015.
But the European Commission’s proposed regulation on lead in PVC goes in the opposite direction from this phase-out, allowing up to 2% lead by weight in a large number of different rigid PVC products, for the next 15 years. As a side effect PVC containing up to 0.1% lead, whether recycled or not, would be permitted to be imported into the EU. Up to 10,000 tonnes per year of lead could be sold on the EU market within PVC products.
This exemption will increase the amount of lead circulating in the European economy, and will create a growing, huge, mountain of lead-contaminated PVC, as more and more new virgin PVC has to be added to retain quality. This contaminated material will one day become waste that needs to be dealt with.
Should lead-contaminated PVC be recycled or landfilled?
The opinion (page 12 and 13) from ECHA’s scientific committees shows that landfilling has the lowest lead emissions, while emissions from recycling (during grinding, milling and service life) are 8 to 12 times higher. It’s also worth noting that it is better from a climate point of view to landfill plastic waste, rather than incinerating it, as almost all plastic is fossil fuel derived and it is therefore better to landfill it (essentially a simple version of carbon capture and storage) rather than burning it in an incinerator.
The EU’s Waste Framework legislation says that landfilling is to be avoided except in cases where it is the environmental best option.
We have seen material from an industry group claiming that ECHA’s committees concluded that recycling is the best environmental option. This is wrong. ECHA was instructed to do its assessment of lead under the condition that land-filling of PVC ends in 2027, so could not consider the landfill option (see ECHA opinion table 1).
CHEM Trust’s view
Stefan Scheuer, Chief EU Policy Advocate at CHEM Trust, said:
“This Commission proposal feels like it’s going back to a dirtier past, when the solution to pollution was dilution. Waste PVC with high lead contamination will be mixed with new materials until lower levels of contamination are achieved. The result is widely-spread pollution and a costly legacy for future generations. Better waste management options were excluded from the outset.
The Parliament should send the Commission back to work on the lead in PVC restriction in order to deliver a European Green Deal for people and their environment. As a matter of principle the EU should ensure that recycled materials are made to the same standards as virgin materials, thus ensure as clean circular economy, not a dirty one.”