Fabian Demicoli

Consultation: Restriction of Lead and its compounds in articles intended for consumer use

 The European
Chemicals Agency has launched a public consultation on the Restriction proposal
for Lead and its compounds in articles
intended for consumer use (EC: 231-100-4, CAS: 7439-92-1).  The
full report on this Annex XV restriction has been published and can be
downloaded from the following link: http://echa.europa.eu/documents/10162/80f7edca-b6c1-4433-8734-854594530db2

Lead has been deemed a non-threshold toxic substance for
neurotoxic and neurodevelopmental effects, in particular in children. This
means that it is not possible to establish a "safe" level of lead in the blood
of children. Consequently, their exposure to lead should be avoided as far as

Children's exposure to lead is still above the highest
tolerable level. All additional exposure to lead, from food or non-food
sources, should therefore be avoided as far as possible. There is hence a need
for further regulation.

Lead and its compounds have a wide use and have been found in
a great variety of applications, some of them being articles intended for
consumer use. Lead is usually present in metal alloys (notably brass), in
pigments/dyes, and to a lesser extent as stabilisers in plastic and as pure
metal. It cannot be determined through a simple analysis which lead compound is
present in a specific material. Neither can it be simply established whether
lead is present as pigment or as stabiliser in a plastic. Therefore, all lead
compounds should be targeted by any further action proposed.

The main route through which children are exposed to lead
from these articles seems to be the mouthing (sucking and chewing) behaviour
exhibited by small children. Of the consumer available articles that are frequently
placed in the mouth by children, and that are not covered by other regulations,
around 10% can be estimated to contain lead. The average lead concentration in
these articles is around 1%. When children exhibit their normal mouthing
behaviour, this lead may cause risk of impaired development of their central
nervous system. The health risk to children who suck or chew lead containing
articles has recently been subject to a restriction under REACH, namely that of
lead in jewellery (entry 63 of Annex XVII).

The action proposed is a restriction in which articles
intended and available for consumer use, which can be placed in the mouth by
children, may be placed on the market only if they do not contain lead above a
limit value of 0.05% by weight. The limit value, which is supported by the
tolerable lead content calculated in this report, should also apply to
individual parts of the articles in question. Such a restriction is aligned
with the similar restriction of lead and its compounds in jewellery items,
which enables a harmonised regulation on lead in the whole range of consumer

Kindly submit comments on the
restriction proposal by Friday 28th
June 2013 on 23952000 or

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