The ECHA Member State Committee (MSC) discussed the inclusion of lead metal in the REACH Candidate List of substances of very high concern (SVHCs), in Helsinki on June, 12th 2018

The industry position was displayed during the public consultation and at the different stages prior to the Committee deliberation. At the meeting, the industry questioned the proportionality and effectiveness of using the REACH Authorisation process to further regulate Pb metal.

This position was shared by several Member States, nonetheless, they finally agreed on the Candidate Listing of lead metal, since all the procedural requirements were met and the necessary features for a SVHC classification – more in particular, its harmonised hazard classification as Toxic to Reproduction (Category 1A) – were found.

The ECHA Candidate List was updated to include Pb metal on June, 27th 2018.

Once the substance is added to the Candidate List, a number of communication obligations are triggered. In particular, under Article 31 (Requirements for safety data sheets) and Article 33 (Duty to communicate information on substances in article):

  • Suppliers of lead metal as a substance or in a mixture should indicate in their Safety Data Sheets that Pb metal is a Candidate Listed SVHC
    • For pre-fabricated lead metal or mixtures (including alloys), a threshold of 0.3% or more applies
    • For Pb powder, or mixtures containing more than 0.03% Pb powder, the threshold of 0.03% or more applies
  • Suppliers of articles containing more than 0.1% Pb by weight must inform business recipients that Pb metal is present when the article is supplied for the first time after the substance is formally included in the Candidate List. In the case of supply to the general public, the same information must be provided within 45 days of a consumer request.

From now onwards, the procedural path will insist on the “prioritization” stage, which is expected to take place in the last Quarters of 2019. As soon as Pb metal is formally identified as a substance of relative high-priority within the Candidate List by the European Commission, a 5-6 years countdown will start.

For more information, see the website of AFEMS (