The European Federation of Associations of Locks & Builders Hardware Manufacturers

Lead on SVHC Candidate list

Substances fulfilling one or more of the criteria defined in Article 57 of REACH can be identified as Substances of Very High Concern (SVHC) and put on the Candidate List for authorisation.

Substances of Very High Concern SVHC can be:

-   Substances meeting the criteria for classification as carcinogenic, mutagenic or toxic for reproduction (CMR) category 1A or 1B in accordance with the CLP Regulation (EU regulation (EC) No 1272/2008 on classification, labelling and packaging of chemical substances and mixtures)

-   Substances which are persistent, bioaccumulative and toxic (PBT) or very persistent and very bioaccumulative (vPvB) according to REACH Annex XIII

-   Identified, on a case-by-case basis, from scientific evidence as causing probable serious effects to human health or the environment of an equivalent level of concern as those above

Once a substance is identified as a SVHC, it is included in the Candidate List. The inclusion in the Candidate List brings duties and obligations for suppliers of the substance, as well as for suppliers of articles containing the substance if the concentration of the substance in the article is above a defined threshold.

ARGE’s recommendation concerning lead being on REACH’s SVHC Candidate List.

On 27th June 2018 the heavy metal lead (Pb) was added to REACH’s ‘Candidate List of Substances of Very High Concern for authorisation’ (‘Candidate List of SVHC’). This triggered certain duties and obligations under the REACH regulation for many companies, including manufacturers of building hardware. In relation to building hardware products, lead is used frequently as a minor addition to alloys of which components (and in some cases the products themselves) are made of. Lead is added because of its chip breaking properties, allowing better and more efficient machining of e.g. brass and steel.

The most prominent duty under the REACH regulation is the ‘duty to communicate information on substances in articles’ (REACH regulation, Article 33). The trigger for this ‘duty to communicate information on substances in articles’ is when components of products (in some cases the products themselves) contain lead in a concentration above 0.1 % weight by weight (w/w). As this obligation impacts many suppliers of building hardware products (e.g. cylinders, door closers) ARGE has prepared a recommendation on how to comply with this and other related obligations. ARGE has also established an example information letter, which outlines which information content suppliers have to provide in order to meet the duties under REACH regulation, Article 33 to act in compliance with the respective REACH obligations. The recommendation and the example of an information letter can be found here.