The European Chemicals Agency (ECHA) published a draft recommendation on Feb. 2 for the inclusion of Lead in Annex XIV (“The Authorization List”) under the European Union’s (EU) Registration, Evaluation, Authorization and Restrictions of Chemicals (REACH) regulation.

If the EU Commission decides to include lead on the Authorization List, manufacturers, importers and downstream users will be prohibited from placing this substance on the EU market unless that entity has an exemption or is authorized for its use under REACH rules.

The EU REACH regulation attempts to protect human health and the environment from the risks posed by hazardous chemical substances. The regulation establishes procedures for collecting, assessing and managing the introduction and use of chemical substances in the European market.

One of these regulatory tools is known as Annex XIV; the Authorization List. Under the Authorization procedure, ECHA can submit recommendations to take currently listed Substances of Very High Concern (SVHC) and add them to Annex XIV.  Once the EU Commission places the SVHC in Annex XIV, the listed substance can longer be introduced into the EU market, unless specific businesses and manufacturing entities apply for authorizations for certain uses. 

It is important to note that these restrictions are only applicable to manufacturing and processing entities operating in the EU. When an importer or manufacturer introduces these substances in their articles outside of the European marketplace, REACH does not apply. Therefore, SVHCs may still be imported into the EU without meeting the authorization requirements of REACH. 

AEM intends to engage with the European Commission regarding this public consultation issue. For more information, please contact AEM Director of Global Standards and Jason Malcore at jmalcore@aem.org, or reach out to AEM's Regulatory Compliance Steering Committee.

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