Comments on ECHA’s Draft 9th Recommendation for Trilead bis(carbonate) dihydroxide (EC number: 215-290-6) and references to responses

The present document compiles the comments received during the public consultation on the draft 9th recommendation for inclusion of substances in Annex XIV of REACH for Trilead bis(carbonate) dihydroxide (EC number: 215-290-6). The public consultation took place between 5 September 2018 and 5 December 2018.

For each of the comments there is also a reference to specific section(s) of a document containing the responses to comments (“Response document”, available at https://echa.europa.eu/documents/10162/13640/9th_recom_respdoc_lead_stabilisers_en.pdf). The responses in the Response document are arranged by thematic block and level of information (see more detailed explanations at the beginning of that document).

PUBLIC VERSION

Content

I - General comments on the recommendation to include the substance in Annex XIV
II - Transitional arrangements. Comments on the proposed dates
III - Comments on uses that should be exempted from authorisation, including reasons for that

I - General comments on the recommendation to include the substance in Annex XIV
Number / Date	Submitted by (name, submitter type, country)	Comment	Reference to responses	
3288
2018/11/26	Germany,
Member State	The use of this substance as a stabiliser in PVC will be banned once the restriction on lead in PVC will come into force. However, the restriction proposal drafted by ECHA foresees to allow the use of recycled PVC for another 15 years with concentra-tions up to 2% of lead compounds which we strongly support.
It remains unclear whether this exact use of recycled PVC is in the scope of the authorisation regime. We therefore recommend including a reflection on the interplay between the restriction of lead in PVC and a potential authorisation requirement for this substance in recycled materials in the final background document.	A.2.05. Interplay between the restriction of lead in PVC and a potential authorisation requirement for leads in recycled materials	
				
3290
2018/11/26	Germany,
Member State	The use of this substance as a stabiliser in PVC will be banned once the restriction on lead in PVC will come into force. However, the restriction proposal drafted by ECHA foresees to allow the use of recycled PVC for another 15 years with concentra-tions up to 2% of lead compounds which we strongly support.
It remains unclear whether this exact use of recycled PVC is in the scope of the authorisation regime. We therefore recommend including a reflection on the interplay between the restriction of lead in PVC and a potential authorisation requirement for this substance in recycled materials in the final background document.	A.2.05. Interplay between the restriction of lead in PVC and a potential authorisation requirement for leads in recycled materials	
				
3344
2018/12/05	ChemSec,
International NGO,
Sweden	ChemSec supports the prioritisation of trilead bis(carbonate) dihydroxide for inclusion in Annex XIV and supports grouping with other lead substances used as stabilisers.	Thank you for your opinion.	
				
3372
2018/12/05	CHEM Trust,
National NGO,
United Kingdom	CHEM Trust strongly supports the prioritisation of trilead bis(carbonate) dihydroxide for inclusion in Annex XIV and agrees with the importance of grouping it with other lead substances used as stabilisers, as proposed by ECHA.	Thank you for your opinion.	
				
3378
2018/12/05	Norway,
Member State	In general, the Norwegian REACH CA supports measures that will reduce the use and emission of lead and lead compounds. We also support grouping of lead substances to avoid substitution with substances with similar properties within the same use categories. We consider the prioritisation criteria to be fulfilled and support that trilead bis(carbonate) dihydroxide  is prioritised for inclusion in Annex XIV.	Thank you for your opinion.	

II - Transitional arrangements. Comments on the proposed dates
Number / Date	Submitted by (name, submitter type, country)	Comment	Reference to responses	
3378
2018/12/05	Norway,
Member State	In general, we are in favour of the shortest LAD slot.	B.1.1.3. ECHA's proposal for latest application dates

Thank you for your opinion.	

III - Comments on uses that should be exempted from authorisation, including reasons for that
Number / Date	Submitted by (name, submitter type, country)	Comment	Reference to responses	
3378
2018/12/05	Norway,
Member State	Norway does not support that any exemptions from the authorisation requirement should be proposed.	Thank you for your opinion.