Regulatory issues

Regulatory framework

From a regulatory point of view, the main driver for improving sustainability within the European Union has been the Waste Framework Directive (EU Directive 2008/98/EC). Other European Directives impact specific sectors, such as the European Directives on End-of-Life Vehicles, Packaging and Waste Electric and Electronic Equipment (WEEE). In addition, many Member States restrict disposal of plastics in landfill through national regulation.

Legacy additives

Legacy additives are substances which are no longer used in the production of new PVC products. Most have been or are being replaced by alternatives on a voluntary basis, but may still be found in recycled PVC. Among these, some stabilisers and plasticisers are subject to regulatory constraints.

Small quantities of heavy metal-based - lead and cadmium – were used in the past as stabilisers to protect PVC from thermal degradation and also as pigments. As part of the VinylPlus programme, the European industry has completely phased out cadmium and is working to substitute lead-based stabilisers by the end of 2015. Alternative stabiliser systems include calcium-based formulations; PVC compounds containing these stabilisers now account for well over half of the European market.

Other types of legacy additives include low-molecular-weight phthalate plasticisers. VinylPlus is working with the wider industry and regulators to move towards non-classified plasticisers which today represent about 85 percent of the European market.

Recycling issues

Recycled waste streams may contain cadmium. The placing on the market of polymers containing cadmium is restricted by an amendment (Regulation 494/2011 of 20 may 2011) of Annex XVII of REACH. This amendment allows higher cadmium content in rigid construction products if the cadmium originates from recycling. The industry is working with the relevant EU authorities to ensure that recycling activities remain sustainable while complying with the current regulatory regime.

An online database of polymers and applications has been developed to support PVC recyclers to comply with the REACH requirements. This tool enables recyclers to access the necessary 'Safety Data Sheets for Recyclers' (www.sdsrtool.com) and published guidance documents.