Legacy additives are substances that are no longer used in new PVC products but that can be present 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.
Over the years, VinylPlus has contributed to discussions on legacy additives by supporting research and a considerable number of studies. Several substances were investigated (e.g. cadmium compounds, lead stabilisers, and DEHP) from several angles. These ranged from worker safety and emission potential to risk assessment models (leaching outdoors and during waste storage, and the resulting human exposure) and socio-economic analysis. Studies are also on-going on substances such as antimony trioxide, titanium dioxide and ADCA which might be subject to restrictions in the future.
ECHA worked on the restrictions under consideration for PVC that contains lead compounds.
In their opinions, respectively adopted on 5 December 2017 and 15 March 2018, ECHA's Committees for Risk Assessment (RAC) and Socio-economic Analysis (SEAC) confirmed that recycling should be considered as an appropriate risk management measure. They proposed a revision of the lead content limits for articles containing recycled PVC, to 1% for soft PVC and up to 2% for rigid PVC. A condition for these revised limits would be that, in soft applications and in specific rigid applications, the lead-containing recycled PVC be entirely encapsulated within a layer of virgin PVC.
In 2018, RDC Environment carried out an evaluation study, Technology and Economic Feasibility of Soft PVC Encapsulation. This study concluded that, while technically feasible for sheets (multilayers), the cost of encapsulation would be prohibitively expensive except for higher-value products. For most of the remaining products (traffic management, roofing tiles, boots for professional use), the technical feasibility of encapsulating the recyclates within layers of virgin PVC is unknown or at least not readily available. Most probably, it is excessively expensive.
VinylPlus supported the companies VinyLoop® and Plastic Planet in the development of their DEHP authorisation review dossiers. Studies demonstrate adequate control of the recycling of soft PVC containing DEHP, as well as socio-economic benefits. The submitted Chemical Safety Reports document the safe use (for workers and consumers) of DEHP in current recycled soft PVC applications. In September 2018, ECHA’s committees published a consolidated opinion in favour of extending the authorisation for seven years.
Want to know more on PVC Recycling and legacy additives: A LEAD ON RECYCLING PVC, by Dr. Mark Everard, Associate Professor of Ecosystem Services, University of the West of England (UWE Bristol).