A draft Danish order "prohibiting the import, sale and manufacture of lead and products containing lead" was notified to the Commission and member states in late December. A three-month standstill period, during which the EU or member states can raise objections, ends on 1 April. Unless this happens then the order will enter into force on 1 November.
Products containing over 50 parts per million of lead would be banned from 1 November, with prohibition effective a few years later for various specific product groups. A wide variety of lead-using products would be affected, including some major markets for the lead industry such as lead-based stabilisers used in PVC plastic, lead roofing materials, ceramic glazes and crystal glass. Components used in the motor and electronics industry would also be affected.
According to the Danish authorities, the order's objective is to "restrict uses which entail either a direct effect on persons or the environment or which...are spread to the environment". The latter issue is particularly significant in Denmark, the government says, because most of its waste is incinerated.
The government argues that problems associated with lead are "largely connected with targeted uses of lead in products". Contributions from each of these may be small, it says, "but in combination become significant". The appropriate response, it concludes, is to "reduce the total emission of lead to all media," which is best achieved by "reducing the use of lead in products as much as possible". On this basis it would be "unnecessary as well as being an impossible task, to carry out a risk assessment for all products containing lead".
With some of its main markets under threat, the European lead industry has roundly attacked the Danish proposals in a detailed critique completed recently. Banning virtually all uses of lead would not be justified on health or environmental grounds and would thus be "disproportionate to a perceived problem," according to the EU association Eurometaux. In many applications that would be affected by the ban, there are no practical alternatives, Eurometaux adds.
Any such ban instituted in Denmark could also be "the thin end of the wedge," leading either to market substitution or legislation restricting the use of lead in products around the EU, according to David Wilson of the London-based Lead Development Association International (LDAI).
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