Disclaimer: The original author of this piece is the European Environmental Bureau (EEB), a member of the EDC-Free Europe campaign

Next week, on 7-8 December, Member States will have the opportunity to discuss three crucial matters with the Commission in REACH’s Committee meeting. There will be a discussion on the restriction of lead in PVC and potential votes on the identification of the chemical substance Resorcinol as an endocrine disruptor along with a potential vote on the use permit of lead chromates in paints. 

The discussions may determine whether the European Union is really looking towards creating a toxic-free environment. These substances have the potential to harm our children, health and the environment and several NGOs have banded together by writing a joint letter pushing Member States to meet their demands. The toxic substances currently on our market should have been phased out years ago and Member States need to urgently act. 

What is at stake: If Member States don’t follow the NGOs petitions in their votes: 

  1. Resorcinol is known to impact the functioning of the thyroid system, which is essential for brain development, in particular for unborn children with irreversible effects.  
  2. The EU will allow lead to re-contaminate the EU circular economy as it will continue to be recycled in PVC for at least another decade.   
  3. Lead sulfochromate yellow and of lead chromate molybdate sulfate red (known as lead chromates) will continue to be manufactured and used in industrial paints in the EU, despite the EU companies removing lead from paint years ago. 

Why Member States should follow the NGO petitions:  

  1. Resorcinol meets the World Health Organisation (WHO) definition of an endocrine disruptor. 
  2. The European Parliament rejected the Commission’s attempt to allow the recycling of lead in PVC since it would mean a contamination of the EU circular economy. It has taken more than 2 years for the European Commission to make a follow up proposal.  
  3. The EU General Court agreed that the authorisation granted by the Commission of the use of lead chromates in paints should have never taken place as it was illegal. 

Damaging Effects of Toxic Substances 

  • Resorcinol is known to impact the functioning of the thyroid system, which is essential for brain development, in particular for unborn children with irreversible effects. 
  • Harmful emissions of lead will continue to be discharged into the environment if it remains in PVC. The highly toxic chemical is known to impair neurobehavioral function, particularly as a result of childhood or foetal exposure and is linked to lower intelligence quotient (IQ). 
  • Exposure to lead chromates can damage children’s brain development, harm the nervous system and causes lung tumours in people and animals.  

Key Demands 

  • Urgently restrict all forms of lead contained in PVC by setting stringent thresholds for lead in PVC, regardless if it is virgin of recycled plastic. 
  • Leniency to lead in PVC should not be possible. Limit transitional periods of lead in PVC to six months maximum. 
  • Rephrase the lead in PVC labelling to ‘WARNING: contains lead’.
  • Refusing the use authorisation application of lead chromates in paints.
  • Clearly identify Resorcinol as a substance of very high concern as a matter of urgency.  


Tatiana Santos, Policy Manager for Chemicals & Nanotechnology at the European Environmental Bureau (EEB)

Lead is highly toxic and there is no safe level of exposure. Lead in PVC is such an old story that it is no longer used in the EU since 2015. Still, two years ago, the Commission attempted to allow the recycling of polluted PVC into new products. Fortunately, the European Parliament vetoed such proposal. We hope the Commission will take full responsibility this time and meet the Green Deal’s objectives to clean the circular economy and the protection of human health and the environment. And it has to do so asap, we are talking about thousands of tonnes of lead that have been placed on the European market in PVC products, every year counts. 

Natacha Cingotti, Health and Chemicals Programme Lead at the Health and Environment Alliance (HEAL)

“The identification of Resorcinol as a substance of very high concern under REACH provisions is supported by robust scientific evidence and is an important credibility test for commitments of the Chemicals Strategy for Sustainability. The substance is a known endocrine disruptor affecting the functioning of the thyroid system, which is essential for children’s development. The severity of the impacts associated to exposure for individuals’ health and quality of life over the long term should provide impetus for Member States to proceed as soon as possible”. 

Notes from the Editor

NGO joint letter to the REACH Committee: https://eeb.org/library/joint-ngo-letter-to-the-reach-committee/