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ClientEarth commented to ECHA on the proposal to restrict the presence of lead compounds in PVC placed on the EU market and raised concerned, in particular, with the derogation envisaged for recycled PVC. This derogation raises two main issues. First, the Proposal does not estimate appropriately the risk of released lead into the environment in a scenario where PVC is recycled. It also assumes that recycling PVC containing lead will have a beneficial environmental and health impact. Second, the derogation creates an enforcement issue and could jeopardise the success of the circular economy.
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