Comments on the proposal to restrict lead compounds in PVC

ClientEarth opposes a proposed derogation that would allow recycled PVC to contain up to 1% lead compounds, arguing that it underestimates environmental risks, creates enforcement loopholes, and undermines the circular economy by associating recycled materials with substances of very high concern.

• The proposed derogation for recycled PVC allows for lead compound concentrations up to 1% weight by weight, which is ten times the limit proposed for virgin PVC.
• ClientEarth contends that the ECHA proposal underestimates lead release in recycling scenarios because it ignores prolonged service-life exposure and assumes recycled PVC will never be eventually landfilled or incinerated.
• The plastic industry has failed to provide evidence of positive environmental or health impacts from recycling lead-containing PVC, relying instead on general claims about resource efficiency and climate change.
• The derogation creates an enforcement risk where national authorities may be unable to distinguish between lead in virgin and recycled PVC, potentially allowing the 'recycled' label to be used to legalise lead levels above 0.1% in virgin components.

APA

ClientEarth (2017). Comments on the proposal to restrict lead compounds in PVC. https://www.clientearth.org/media/gt0lae2j/clientearths-comments-on-echas-proposal-to-restrict-lead-compounds-in-pvc-ce-en.pdf

Chicago

ClientEarth. Comments on the proposal to restrict lead compounds in PVC. 2017. https://www.clientearth.org/media/gt0lae2j/clientearths-comments-on-echas-proposal-to-restrict-lead-compounds-in-pvc-ce-en.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=Comments on the proposal to restrict lead compounds in PVC |date=September 2017 |url=https://www.clientearth.org/media/gt0lae2j/clientearths-comments-on-echas-proposal-to-restrict-lead-compounds-in-pvc-ce-en.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2017comments, author = {{ClientEarth}}, title = {{Comments on the proposal to restrict lead compounds in PVC}}, publisher = {ClientEarth}, year = {2017}, month = sep, url = {https://www.clientearth.org/media/gt0lae2j/clientearths-comments-on-echas-proposal-to-restrict-lead-compounds-in-pvc-ce-en.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }