PVC in annex III of the RoHS directive: a wrong approach without scientific justification, which threatens a significant part of the whole European economy

The Parliament Magazine and the European PVC and plastics industries invited EU policymakers and stakeholders to a roundtable discussion outlining the lack of scientific arguments for potential substitution of PVC in electrical and electronic equipment within the recast of the RoHS Directive, and the consequent potential impact on a significant part of the European economy.

The recent vote in the European parliament's ENVI committee to include PVC within Annex III of the RoHS recast, as a substance of priority review for potential substitution, is unjustified in the view of the European PVC and plastics industries.

The inclusion of PVC in Annex III is unjustified from a life cycle comparison perspective, as the material was, between 2000 and 2006, investigated thoroughly by the European Commission on European Parliament’s request, as part of the Horizontal Initiative on PVC and compared with alternatives. The clear conclusion from the latter investigation was that there was no justification to discriminate against PVC in any application. As there is nothing new, the European PVC and plastics industries do not see any reason to repeat this investigative process again.

The progress made by the PVC industry over the last 10 years towards sustainability, through its Vinyl 2010 voluntary programme, has been significant and concrete. Innovations and technical development have made PVC formulations more sustainable and effective, helping the industry to demonstrate the safety and environmental benefits of PVC.

Vinyl 2010's sustainability target achievements are not only a great example of self-regulation but are also in line with EU policy on reducing emissions and lowering energy consumption. This makes it all the more dispiriting that PVC has been targeted for inclusion within this annex III.

The roundtable debate provided opportunities to discuss the methodology that the industry supports to control the use of substances as part of RoHS.

The Life Cycle Assessment of PVC and of Principal Competing Materials study (2006)
Dr. Martin Baitz
Director Process and Material Sustainability, PE INTERNATIONAL GmbH

The Life Cycle Assessment of PVC and of Principal Competing Materials study (2006)
Klaus Berend
Head of Unit G/2 Chemicals, DG Enterprise

Social and economic impact assessment
Alexandre Dangis
Managing Director, EuPC

View photos from the event