NGO letter to REACH committee on the restriction proposal for lead stabilisers in PVC

On 14^th November 2019, ClientEarth, together with many other environmental organisations, have written to national governments to dissuade them from opening the gate to a toxic circular economy.

In the context of a new restriction of lead in PVC, the Commission is proposing national governments to allow a much higher level of lead in recycled PVC compared to virgin PVC.

Lead is a famously highly toxic chemical which can impair neurobehavioral function, particularly as a result of childhood or foetal exposure and is linked to lower intelligence quotient (IQ).

The letter calls on national governments to reject such double standard because:

(1) the proposal relies on flawed assumptions to conclude that recycling PVC containing lead will have a beneficial environmental and health impact;

(2) as a matter of fact a higher level of lead in recycled PVC goes against the EU objective to transition towards a circular economy;

(3) recycling is not an adequate waste management option for PVC containing lead.