UK opposes EC moves on PVC

Support should be given to the PVC industry's voluntary environmental initiative rather than new legislation, the Department of the Environment, Transport and the Regions has said in a draft response to the European Commission's Green Paper on PVC.

Earlier this year, the PVC sector unveiled proposals which it hopes will form the basis of a voluntary agreement in place of legislation (ENDS Report 303, pp 29-31 ). The programme covers PVC manufacture and waste management and the use of stabilisers and plasticisers - but it falls well short of the tough recycling targets and programmes to phase out hazardous additives sought by environmental groups and countries such as Sweden and Denmark.

The Green Paper, prepared by the Commission's Enterprise and Environment Directorates, described the industry initiative as "an important step" - but added that its success would depend on more ambitious targets for reducing the use of hazardous additives and waste recycling (ENDS Report 306, pp 40-41 ). It also suggested that PVC products which cannot easily be recycled could be phased out.

The DETR has issued copies of its draft response to interested parties for comments. A Commission Communication on PVC, setting out its policy proposals, is due early next year.

  • Life cycle assessment: The DETR questions the Green Paper's assumption that there is a need for specific legislation on PVC in advance of a full examination of its life cycle. The Commission would argue, however, that there has already been substantial research into all parts of the plastic's life cycle, and it was this information which led it to concentrate its own research on end-of-life issues.

    Evidence of benefits would be needed to support controls on the use of PVC, adds the UK response. To address this, the DETR will shortly publish a life cycle assessment (LCA) of selected applications and some common alternatives (ENDS Report 292, p 35 ). This "could then form the basis for further LCAs on specific PVC uses or products and their alternatives in a European context."

    This emphasis on using LCA to go back to the beginning of the debate closely mirrors the PVC industry's initial response to the Green Paper in July. The European Council of Vinyl Manufacturers (ECVM) claimed that the Commission's focus on waste management was misplaced because similar conclusions would be reached for other materials if they were examined in the same way - although PVC's recycling rate of 4% is clearly comparitively low.

    "Any in-depth review of a material must consider its whole life cycle," according to ECVM chairman Jean-Pierre Pleska. Such a review also needs to be set against an understanding of alternative materials, he said.

    Greenpeace argues that LCAs must be capable of incorporating and weighing the hazardous nature of the substances concerned. This, it says, is the "central problem" with PVC, and "subjective decisions regarding the weighting given to the hazardous substances involved compared to other environmental impacts is a potential source of bias that would affect the overall conclusions of any LCA." A wide range of materials can be used for many PVC applications, it adds, so the choice of which materials to study would similarly affect the result.

  • Voluntary or regulatory approach? The industry's voluntary commitment will allow it to operate in a "sustainable" manner, says the DETR. Governments, the Commission and environmental groups should work with the industry to set targets and establish monitoring and verification procedures.

    Greenpeace dismisses this as "a gross misuse" of the term "sustainable" and an "astonishing" interpretation of a set of "minimal measures that will have little effect on the overall environmental impact of PVC."

  • Contravening OSPAR? Greenpeace argues that the DETR's response shows that it is "unwilling to implement the binding commitment made under the OSPAR Convention to cease discharges, emissions and losses of hazardous substances by 2020." Nine of the 27 chemicals on the OSPAR list for priority action are used in PVC or emitted during its manufacture, use or disposal.

  • Economic and social impacts: The PVC industry "is strong in the UK," notes the DETR, and "the potential consequences of change are considerable, although any adverse effects would be partly offset by new business opportunities." It calls on the Commission to conduct an assessment of the environmental, economic and social costs and benefits of the options.

  • Metal stabilisers: The DETR supports the PVC industry's voluntary commitment to phase out cadmium stabilisers within a year, and the development of commitments on lead. The need for measures to promote substitutes should be explored when risk assessments being conducted under the EC's existing substances programme and by industry have "satisfactorily demonstrated that substitutes are less harmful."

    In contrast, the Danish Government recently proposed legislation to phase out most lead products, including stabilisers in PVC, over the next few years. And Scandinavian plastics companies have pledged to remove lead from plastic pipes by 2002.

  • Phthalates: Any measures to restrict phthalate plasticisers should be considered in the light of risk assessments being conducted under the EC programme, the DETR says. More information on the impact of alternatives, such as adipates and citrates, should be obtained from industry urgently.

  • Waste management: The industry's voluntary commitments on recycling offer the "best way forward," says the DETR. It could support efforts to find "economically feasible" ways to divert waste from incineration "on a non-mandatory basis." There is no sound basis for setting chemical recycling targets at this stage, it says.

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