ECHA’s recent proposals on lead metal could cause significant disruption to users of lead solder
As we highlighted in our recent advisory, the European Chemicals Agency (ECHA) and the European Commission have launched a public consultation and call for information on proposals to include lead metal to the REACH Authorisation List. If it does make it onto the list then all uses of lead, including lead solder, (and all associated import and supply) would become illegal after the ‘sunset date’ unless authorisation has been granted or an exemption applies.
Lead has traditionally been used in solder as it results in strong joint formation, it is easy to use, has a lower melting point than lead-free alternatives, and is often cheaper.
Solder is usually considered a ‘mixture’ under REACH and this means the supply of lead solder to members of the public is already banned under a restriction in Annex XVII of REACH. In addition, use of lead in many applications is already regulated through the RoHS Regulation.
“Industry has moved away from the use of lead solder in many applications but has not been able to completely replace it at this time,” explains Richard Bishop, Senior REACH and CLP Commercial Consultant.
“Including lead metal in Annex XIV of REACH will have significant consequences for those using lead solder for industrial and professional purposes, as well as those that supply it for these uses,” Richard continues. “If lead makes its way onto Annex XIV, then all uses of lead solder would become illegal after the ‘sunset date’, unless authorisation has been granted or an exemption applies. In this situation, companies would need to find substitutes to lead solder, or cease using it.”
Given the extent of its use in soldering products, ECHA’s proposal has the potential to cause significant disruption to businesses and the marketplace.
“It is important that users and suppliers of lead solder participate in ECHA’s consultation process, as well as the European Commission’s call for information,” Richard stresses. “The more information ECHA has, the more informed its decision-making process will be.”
Companies have until 2 May 2022 to provide comments to ECHA’s consultation and the European Commission’s call for information to help inform the decision on the proposal.
The consultation and call relate to all uses of lead, not just lead solder. Lead is used in a broad variety of well- and lesser-known applications, from lead-acid batteries and electronic components to radiation shielding, construction products and specialty applications including linings, sheathings and constituents of glass and steel. This is the last formal opportunity companies have to influence the process so it is important to provide comments.
If you are unsure how to go about participating in ECHA’s public consultation and would like to have an informal chat with our experienced REACH team, please get in touch at [email protected]
