Lead (Pb) in PVC articles: further restrictions

Lead is a toxic substance that affects the development of the nervous system, causes chronic kidney disease, and has adverse effects on blood pressure. 

Although no threshold levels have been established for neurodevelopmental effects in children and for renal effects, the European Food Safety Agency has stated that current human exposure to lead from food and other sources still exceeds tolerable exposure levels and causes adverse neurodevelopmental effects in children.

Lead stabilisers increase the thermal stability of PVC during compounding and article production. They also protect PVC from photodegradation. Industry in the Union voluntarily phased out the use of lead stabilisers in PVC compounding and PVC articles and reported that this process was successfully completed in 2015. 

PVC articles containing lead, in particular construction products, have a long lifetime and remain in use for several decades, after which they become waste when disposed of and can be recycled, with the possibility of lead being reintroduced into products via the recovered PVC. 

The REACH Annex XV dossier showed that 90% of the estimated total emissions of lead from PVC articles in the Union in 2016 will come from imported PVC articles due to the phase-out of lead stabilisers in the Union.

In order to facilitate the enforcement of the proposed restriction, it is appropriate to restrict all lead present in PVC, irrespective of its intended function.

On May 8, 2023, the European Union (EU) issued Regulation (EU) 2023/923 to revise the restriction of lead and its compounds falling under entry 63 to Annex XVII of Regulation (EC) No. 1907/2006 ‘Registration, Evaluation, Authorization and Restriction of Chemicals (entry 63 to Annex XVII of REACH). 

The latest amendment restricting lead to 0.1% by weight of PVC material became effective on November 29, 2024. 

• PVC articles containing recovered flexible PVC are allowed to contain lead until 28 May 2025 with a limit of 1.5% by weight.
• Certain PVC articles containing post-consumer rigid PVC are allowed until 28 May 2033, provided that the post-consumer rigid PVC contains less than 1.5% lead by weight. These PVC articles containing post-consumer rigid PVC are profiles and sheets for certain building and civil engineering applications, decking and terraces, certain interior building applications and certain multi-layer pipes and fittings.