Legacy additives are substances whose use in PVC products has been discontinued but that are contained in recycled PVC. Since the use of legacy additives may be restricted by legislation, VinylPlus is committed to addressing the issue in cooperation with regulatory authorities.
In 2015, studies by BiPRO and FABES were completed. The BiPRO study had been commissioned by the European Commission to “assess the possibility of granting a derogation to specific types of plastics and rubber waste in the EU waste list”. The FABES study had been commissioned by VinylPlus in order to evaluate migration models for cadmium, lead, tin and zinc in rigid and flexible PVC (including DEHP for the latter).
According to the FABES study, the levels of migration of substances from recycled PVC are very low, and hence water used to wash recycled PVC meets the most stringent environmental standards. For this reason, the European PVC industry remains convinced that the recycling of PVC waste from B&C (building and construction) products offers a manageable and cost-effective way to keep legacy additives in their safest place and represents the best option in terms of resource and energy efficiency, as well as waste treatment hierarchy.
In order to consolidate the results of the FABES study, additional measurements are currently being made.
RoHS 2 Directive
As reported in last year’s VinylPlus Progress Report, in 2014 the European Commission appointed the consultancy Öko Institut to produce a report on 21 substances that could be prioritised for restriction in electric and electronic equipment (EEE) under the RoHS 2 Directive. Based on the methodology proposed by UBA, PVC was included in the Öko Institut’s prioritisation list for possible future restriction. No concrete intention to restrict PVC has been announced. The European Commission is now expected to publish a final methodology paper.
The tool developed by EuPC and PRE to help recyclers prepare Safety Data Sheets for Recyclates (SDS-R) continued to be updated in line with the Globally Harmonised System (GHS), while taking into account the status of the REACH regulation. In 2015, the tool was translated into seven additional languages and is now available in 14 languages.