Flawed methodology could place unnecessary restrictions on how plasticizers are made and where they’re sold, according to the paper “Review of the ECHA ‘PVC and its Additives’ Investigation Report” written by an Eastman product stewardship and advocacy expert. It was presented at the PVC 2024 conference.
Scott Boito reviewed a 2023 European Chemicals Agency (ECHA) investigation into polyvinyl chloride (PVC) additives. Among the findings in his report are:
- All additives are environmental risks “based on a pragmatic approach applied in absence of a more complete set of data.”
- PVC microplastics and all additives are persistent and bioaccumulative and, therefore, environmentally hazardous.
- Alternatives need to be developed for existing substances.
The ECHA report will be used by the European Commission to propose restrictions on PVC and its additives. But deficiencies in the report could create unnecessary obstacles for formulators and users, Boito said. Among them:
- Researchers miscategorized some substances under study. That led to confusion among participating stakeholders submitting substances to be analyzed.
- The report ignored existing information in the ECHA’s Registration, Evaluation, Authorisation and Restriction of Chemicals Regulation (REACH) showing that many of the substances targeted by the report aren’t hazardous.
- The report assumed all additives leach at similar rates under similar conditions. That assumption spawns negative environmental perceptions without basis.
- The report failed to recognize that several nonhazardous plasticizers and stabilizers have already been used by formulators for years.
The ECHA will not admit flaws in the report, Boito said, nor will it make revisions — regardless of any evidence presented. Nonetheless, Eastman is part of several trade groups meeting with European authorities to either get the report revised or diminish reliance on the report in future regulatory efforts.
Boito said Eastman customers can get involved by submitting comments and attending meetings about the regulations to provide real-world examples. Further action is vital to keep the marketplace for those customers’ products as open as possible.
“We appreciate any and all support we can get from our value chain partners in these endeavors,” he said.
Read the ECHA report and Boito’s response.
