A new report by NGOs lays down why the EU must ban polyvinyl chloride (PVC) if it wants to comply with its own chemicals law. The organisations analysed why the recent report by ECHA supports phasing out PVC as the most effective and future-proof risk management measure.
Christine Hermann thanks Dolores Romano for her contributions and collaboration in the drafting of this article.
The plastic Polyvinyl chloride (PVC) is one of the seven commodity polymers which dominate the global plastics market already today and a further substantial increase in demand for PVC in the construction sector is expected (PlastChem 2024). PVC as a material can however not be used without the additives which give it the required properties. What is however alarming, is the identification of roundabout >1.300 chemicals in relation to PVC of which more than 600 are chemicals of concern (PlastChem, p. 59). Little relief gives the finding that only two percent of the substances that were analysed in PVC are categorised as non-hazardous (PlastChem 2024, p. 61). Particularly soft PVC requires in total more additives (in the number of additives, function and their concentration in PVC) than other plastics.
Poly(vinyl chloride) is a complex plastic system. Individual components of the PVC system, including residual vinyl chloride monomer and certain additives, may pose risks of harm to human health as most of these components are not covalently bound to the polymer matrix.
EC, 2022b. The use of PVC in the context of a non-toxic environment.
Already more than 24 years ago, the European Commission published a paper pointing to the many issues PVC causes for the environment and human health since decades and until today no major regulatory action has been taken.
After PVC was included in the Commission’s Restrictions Roadmap, the EU’s workplan to ban the most hazardous chemicals, the European Chemicals Agency (ECHA) was asked to investigate the risks posed by PVC and its additives. The report published last autumn looked into many but not all uses of PVC and prioritised for the further assessment a limited number of additives, given the sheer number of chemicals added to PVC products. The report highlighted that PVC additives and PVC microplastics pose a risk to human health and the environment and that alternatives are available for the uses they analysed.
Hélène Duguy, legal expert at ClientEarth states:
When there’s sufficiently serious evidence that damages to the environment or people’s health may occur, the EU is legally bound to act. That’s the essence of the precautionary principle, which is a principle underpinned in EU law. The harms of PVC to the environment and health have now been too well-documented, including by the EU authorities. There’s no reason to stall any further.
ECHA also concluded that the relatively low price of PVC compared to the alternatives, would cause significant cost to substitute PVC in some uses, such as pipes and window frames However, concluding on PVC to be cheap fails to properly account for the costs during its whole lifecycle. And addressing only some groups of additives, besides leading to regrettable substitution, does not address the remaining risks of PVC production, use and disposal.
ECHA rejects a phasing out of PVC, especially with the socioeconomic argument of the low costs of PVC compared to alternative plastics/materials. However, this argument is only applicable if the additional costs of the post-consumer phase—especially for the separate collection and disposal of PVC—are not taken into account. If included, PVC becomes an expensive plastic.” (Lahl & Zeschmar-Lahl, 2024, p. 10).
Indeed, the problem with PVC goes far beyond the concern of additives and the waste treatment cost alone. The ECHA report also highlighted the severe concern related to the release of microplastics from PVC, especially during professional handling and at the end-of-life treatment. The release of microplastics might not be an issue unique to PVC, however, PVC’s uniqueness relies on the high amount of hazardous additives that these microparticles spread throughout the environment and into living beings. The stock of PVC particles and additives will therefore be further build up in the environment and increase the risk of exposure to humans and other living organisms.
A word from Prof. Bethanie Carney Almroth, Department of Biological & Environmental Sciences, University of Gothenburg:
Plastics are now ubiquitous, contaminating every niche on the planet, including the deep ocean, the atmosphere, and human bodies. The complexity and volumes at which global societies are producing these materials, comprising thousands of polymers and chemicals, far outpace our ability to mitigate the harm they cause to human and environmental health, thereby moving us outside the safe operating space for humanity. Multiple lines of evidence indicate that the production and release of both macro- and microplastics has direct and indirect impacts on stability of Earth system functions, impacting climate change, biodiversity changes, nutrient cycling and land and water systems. Plastics will continue to accumulate in the environment unless drastic efforts to reduce production are taken. In efforts to reduce plastics production, and thereby plastics pollution, we will need to apply principles including the waste hierarchy, essential use paradigms, and safety and sustainability criteria. Polymers like PVC should be banned, based on their known toxicity, including vinyl chloride monomers, chemicals commonly used in PVC products (e.g. phthalates), and the toxicity of PVC microplastics.
Although the ECHA report identifies that PVC as a material and its additives pose a serious risk for health and the environment, and although these findings already provide sufficient evidence to support strong regulatory action, the agency does not propose a REACH restriction as an appropriate matter. According to the legal expert Helene Duguy from ClientEarth, this is a clear example where “the EU is legally bound to act. That’s the essence of the precautionary principle, which is a principle underpinned in EU law. The harms of PVC to the environment and health have now been too well-documented, including by the EU authorities. There’s no reason to stall any further.”
Besides the concerns identified in ECHA’s report, EEB and other NGOs list further aspects that complement the bigger picture around PVC, including the risk from manufacturing, uncontrolled burning, accidents from the transport of the highly toxic feedstock of PVC and waste treatment problems that gives no perspective for a future sustainable use of PVC in a toxic-free circular economy.
According to our estimates, the mass of PVC in stock in Europe has now grown to about 160 million tonnes. Neither material recycling nor energy recovery together with mixed municipal waste can solve this stock problem. PVC must therefore be collected separately, and the industry must offer a technical solution for this waste. But the list of failed solutions is long. In the end, a technical solution can be very expensive for the industry.
Prof. Uwe Lahl & Dr. Barbara Zeschmar-Lahl
Accidents are something that also additive substitution and emission reduction techniques cannot avoid. Environmental advocates with long experience around PVC warn that “it’s only a matter of time before we see another crisis like the East Palestine, Ohio train derailment disaster. To keep this from happening again, it is critical that we prevent PVC production, use, and disposal ( Mike Schade, Director, Mind the Store, Toxic-Free Future. This is supported academia, as professor Terrence Collins (Teresa Heinz Professor of Chemistry at Carnegie Mellon University) predicts: “Fires burning PVC create dioxins which can wreck development and ruin lives in myriad living things including humans. While it was obvious decades ago, few would have entertained the idea that there would be massive fires raging across Europe (and in other places) and a war torching the built environment of 40+ million people.”
The risks we are facing around PVC and its troubled lifecycle are obviously not a matter of the past and remain more relevant than ever. “So why are we still doing this when there is a golden opportunity to ditch PVC for alternatives that make more sense?” wonders one of the NGO report’s co-authors Dorota Napierska, Toxic-Free Circular Economy Policy Officer at Zero Waste Europe states. “We have more than enough evidence to act now – that’s why we’re calling on EU policymakers to restrict the use of PVC where it can be replaced by safer and more circular alternatives”
The massive support of more than 60 NGOs, that signed already the call for action to ban PVC in the weeks before the ECHA report publication remains standing and the demand remains the same. PVC ticks all the boxes that justifies regulatory actions under the REACH regulation, thus the EU commission EU has “legal duty” to ban PVC.
#BanPVC #ToxicFreeFuture
