Legacy additives are substances whose use in PVC products has been discontinued to a major degree but which are contained in recycled PVC such as it is the case of a number of low molecular weight phthalate plasticisers, as well as lead and cadmium stabilisers. For recyclates containing low molecular weight phthalates, the Competent Authorities for REACH and CLP (CARACAL) issued their interpretation in March 2013.
According to that, recyclers have two options when recycling waste into a pellet, regrinding or regranulating PVC containing a substance subject to Authorisation:
- They can follow the REACH Authorisation process
- They can sell the recyclates as waste after the February 2015 sunset date, in which case the recyclate will not be subject to Authorisation but to waste legislation.
In September 2014, ECHA’s Committees for Risk Assessment (RAC) and Socio-economic Analysis (SEAC) issued draft opinions expressing their support to authorise three recycling companies – Vinyloop Ferrara, Stena Recycling and Plastic Planet – to formulate recycled soft PVC containing DEHP in compounds and dry blends and for the industrial use of recycled soft PVC containing DEHP in polymer processing by calendering, extrusion, compression and injection moulding to produce PVC articles. These proposed Authorisations are time limited (four years for use of DEHP in PVC applications and 7 years for recycling of PVC articles made with DEHP) and company specific. The proposed Authorisations have no impact on the existing restrictions in toys and childcare articles, and cosmetics. The final decision on Authorisation rests with the European Commission.