Urgent – Your action needed – ECHA’s plan to include lead in the list of substances subject to authorization (Appendix XIV of the REACH Regulation)

If the material LEAD would be banned from use throughout Europe this would have a big impact for many fields of conservation-restoration and beyond!

Please read the background and explanation our cooperation partner ICOMOS is disseminating and share this information with your members and institutions in your country:

The European Chemicals Agency (ECHA) is carrying out a public consultation – deadline Monday 2nd May –  with regards to the possible inclusion of lead in Appendix XIV (Authorization list) of the REACH Regulation, which aims to protect health and the environment. If lead is added to the list of substances requiring authorization for use or handling, this means its uses will be subject to the European authorization process (authorization to be requested either by the “downstream user” or by a user/supplier up the chain) and it will have to be demonstrated, among other things, that the risks for the uses are controlled. The objective of the authorization process is to replace hazardous substances. Formulating such authorization requests are time consuming and complex processes with no guarantee of a positive result. This would of course have a major impact on a substantial part of the cultural heritage sector – and in particular on the art of stained glass and the restoration of Europe’s vast heritage of historic medieval to modern stained glass.

Therefore ICOMOS, ICOM, E.C.C.O, ICOMOS-Corpus Vitrearum ISCCSG and ICOM-Glass are jointly issuing the attached statement strongly urging the ECHA and the European Commission to exclude the use of lead in the fabrication, conservation and restoration of stained glass and other cultural goods from its proposed ban. There is a need for an official and permanent regulation that the art and production of stained glass in particular, but also the use and handling of lead in other cultural heritage sectors, is permanently removed from the list or given a permanent exemption from the EU Chemicals Regulation and all directives on hazardous substances (e.g. 2011/65/EU).

This statement will be sent to ECHA and the European Commission – as well as to other key actors in Europe – and uploaded on the consultation websites.

  • Download the statement in English here
  • Download the statement in French here

We encourage the E.C.C.O. members to also make submissions via the official ECHA consultation webpage below and to encourage your members and networks to do likewise. For that purpose, please find below model letter which you can adapt as you wish or use parts of for the submission.

  • Download the letter template here

The deadline is however EXTREMELY SHORT : 2nd May!

You can also send the letter, among other, to:

ECHA official online consultation:

The Consultation on the draft recommendation for inclusion of lead in the Authorisation List –  (EC Number: 231-100-4)  includes two parts (you can switch the language at the top right hand of the page)

Paste main observations – in the field “Comments on uses (or categories of uses) that should be exempted, including reasons for that” and upload the full letter under Attachment IV.

This comes in form of a questionnaire (see attached). You do not need to answer all the questions, only those that seem relevant and/or for which you have information to give. It is in English, but you can answer in any EU language. Once completed as is, or on your letterhead, you must upload it to that page. We suggest that you add the model letter we have prepared as an appendix to the questionnaire.

For more information on the process of including substances on the Authorization List, please visit the ECHA website : Recommendation for Inclusion in the Authorization List- ECHA (europa.eu).

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