---
title: "EU: Lead to be proposed as a new REACH SVHC"
description: "EU: Lead to be proposed as a new REACH SVHC"
---

[Commentary & Analysis - Compliance & Risks](https://go.adherent.com/commentary-analysis-old)

# [EU: Lead to be proposed as a new REACH SVHC](https://go.adherent.com/commentary-analysis-old/eu-lead-proposed-new-reach-svhc)

 Written by [kshine](https://go.adherent.com/commentary-analysis-old/author/kshine) | Dec 20, 2017, 5:06:25 PM

The European Chemicals Agency posts on its website announcements of the intentions of EU Member States to propose substances to be Substances of Very High Concern (SVHC). Recently lead metal was added to the Registry of Intentions for SVHCs which will be proposed by Sweden, potentially by the 7th February 2018. Proposed SVHCs are added to the candidate list if they meet the criteria of Annex 57 of REACH and as lead metal has an EU harmonised classification of reproductive toxin category 1A, it clearly does meet this criteria and so it should be added to the candidate list.

What happens next is less certain. Clearly once it is an SVHC, this will affect manufacturers, importers and suppliers of a wide variety of products that contain lead metal, which will include vehicles, aircraft, buildings (lead sheet is still widely used) and electrical equipment. This requirement will include electrical products that comply with RoHS but where lead metal is used in an exempt application – for example in high melting point alloys (as used in bridge rectifiers and power semiconductors for instance), and in machinable alloys where it is used at \>0.1%. Disclosure to customers will be required if the equipment being supplied contains any articles, such as a machined leaded brass part or a bridge rectifier which contains \>0.1% of lead in these simple article. These applications are covered by RoHS exemptions so are permitted by RoHS. It is advisable that component suppliers should inform their customers if any RoHS exemptions are used and so this information may be sufficient to comply with REACH Article 33. However, some suppliers will declare components as RoHS compliant if they use a restricted substance in an exempt form; in this case reporting the presence of lead as an SVHC would still be necessary. Note also that products falling out of scope of RoHS, for example those used exclusively in aircraft, rail or defence are less likely to be RoHS compliant and therefore the requirement to declare the presence lead as an SVHC is likely to be common.

After inclusion in the Candidate List, the European Commission would consider what risk management options are necessary. For equipment in scope of RoHS, there should not need to be any further restrictions, as RoHS is supposed to eliminate risk of harm. However inclusion in Annex XVII restrictions or Annex XIV, substances subject to authorisation, will be considered. If lead metal is included in Annex XIV, this would require EU-based industry to request and obtain authorisation for:

- Wave and surface mount soldering processes with tin/lead solder, including rework and repairs;
- Production of alloys that contain lead;
- Electroplating processes for coatings that contain lead;
- Any lead casting processes using ingot as feedstock, e.g. to make lead radiation shielding and lead weights;
- Processes that use lead metal to manufacture lead chemicals may be affected unless the lead metal can be regarded as a transported intermediate, such as for lead acid batteries, for lead-based glass and ceramics (e.g. piezoelectric devices, ultrasound transducers, dielectrics, glass diodes, resistive layer on chip resistors, optical leaded glass, etc.)

Although lead metal is already extensively regulated, but it has many different uses, most of which have no alternatives.

To find out how you can stay on top of changes to this ever evolving regulation and similar chemical regulations around the world, [talk to us](http://www.complianceandrisks.com/talk-to-us/).

 

***Author: Dr Paul Goodman, RINA Consulting, knowledge partner with Compliance & Risks***

[View full post](https://go.adherent.com/commentary-analysis-old/eu-lead-proposed-new-reach-svhc)

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