Here is a brief update on three specific tasks and projects which ARGE is currently engaged.
Lead (Pb) in ‘keys and locks, including padlocks’
Under the EU REACH Regulation, Annex XVII, entry 63 it is permitted to use the heavy metal lead (Pb) in alloys of which ‘keys and locks, including padlocks’ or components for these products are made. In absence of any scientific data of lead release of these products, especially keys, this permission is based on a derogation stated in this entry 63. Following a request of the European Commission (EC), in H2/2019 ECHA investigated whether this derogation (as well as derogations for some other products) shall remain or shall be discontinued.
ARGE provided extensive information not only to ECHA, but also directly to EC, underpinning ARGE’s request to continue allowing lead (Pb) to be used in ‘keys and locks, including padlocks’.
End-June 2020 ECHA published its respective ‘Investigation Report’, coming to the same conclusion as it is ARGE’s position. ECHA states in its report: “Currently there are no technically and economically feasible alternatives to lead in brasses and nickel silver in keys and locks, including padlocks.” ECHA further writes: “Industry is advised to collect migration data in order to demonstrate compliance with the migration limits in entry 63 should the derogation be removed.” It is now up to the EC to decide how to proceed. ARGE, in any case, will not only continue but also intensify its commitment to support manufacturers in developing and implementing strategies which take into account the increasing legal and administrative challenges when using lead as a substance in alloys of which building hardware products, respectively their components, are made of.
EU Waste Framework Directive: SCIP Database
SCIP is the database for information on Substances of Concern In articles as such or in complex objects (Products) established under the EU Waste Framework Directive (WFD). Companies supplying articles containing Substances of Very High Concern (SVHC), as e.g. lead (Pb), on the market of the European Union have to submit information on these articles to ECHA, as from 5th January 2021.
This SCIP database exists as a prototype version already, but substantial questions concerning how information can be provided are still unanswered. As various building hardware products contain lead, ARGE has been actively following the development of the preparation of the SCIP database, and will provide a recommendation on how to meet this legal requirement in autumn 2020.
ARGE EPD (Environmental Product Declaration)
In 2016 ARGE established industry representative EPD for 14 product lines. These EPD were issued according to the then relevant European Standard, EN 15804. In 2019, a revised version of this standard was published (EN 15804+A2:2019). As the validity of the 14 ARGE EPD will expire 5 years after the issuance, end of 2021, ARGE evaluates options for re-issuing EPD under the revised standard. Of the existing EPD, one EPD will not be required anymore in future, namely the one for letter boxes. On the other hand, some ARGE members inquired already for additional EPD for product lines not covered yet. ARGE will liaise with its members within the next months, and subsequently will define together with them about the future of the ARGE EPD.
So far, the input received from members indicates that there will also be a demand for ARGE EPD in the years to come, not only, but also against the background that there seems to be a tendency towards linking EPD closer with the Construction Products Regulation, but also in relation to plans for including EPD data in BIM (Building Information Modeling).