Eppa-Profiles Reach Regulation

REACh Regulation

What is the REACH Regulation?

The Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) aims at ensuring high levels of protection of human health and the environment while enabling the free circulation of substances on the European market. It is applicable to the whole value chain of products. As the title indicates some substances are subject to registration while others need to be authorized for a specific use. Finally, the EU has decided that the use of some substances should be restricted completely.

How does REACH concern our industry?

Among others, but in particular due to the use of recycled material, plastic converters are subject to the regulation. REACH is substance content based and not emission based. Hence, manufacturers have, for instance, to make certain that sufficient information is communicated with articles sold into EU, to allow their safe use (Article 33). Furthermore, they have to monitor the content of dangerous substances in their products and handle these with the necessary care. For profile manufacturers there are essentially three substances which have or soon may have a critical status under REACH:

  1. Cadmium: this substances has already been phased out by our industry. For remainders present in recyclate (see explanation below) an exemption has been created under REACH.
  2. ADCA: this foaming agent is used by some manufacturers. According to the current agenda of the EU the use of this substance should soon be subject to authorization.
  3. Lead stabilizers: Stabilizers containing lead stearate have been used in the past and have been progressively substituted since 2002. However, windows that are recycled now still contain these stabilizers. Using these recyclates means they will be channelled in new profiles by co-extrusion. As these additives are embedded in the matrix they do not represent a risk to human health.  They do not migrate out of the PVC. A restriction in the use of lead in recyclates would endanger the recycling activities of the whole industry. As it is currently not economically feasible to remove lead from the recyclate a restriction would impose a de facto ban on recycling of old windows.

The official statement in accordance with Art. 33a REACH Regulation can be downloaded here.

What are EPPA’s proposals?

As construction products windows should not be covered by REACH legislation but by the Construction Products Regulation in this respect. Basic Work Requirement 3 has the potential cover the management of dangerous substances sufficiently.

Considering that the CPR has not yet been implemented fully, an exemption for lead should be created similar to the one existing for cadmium. This exemption should be based on thorough scientific research bridging the gap until lead stabilizers do no longer exist in windows in measurable quantities.