From 1 March 2018, the harmonised classification and labelling (CLH) for lead metal (9th ATP to CLP) will formally apply. From this date, lead metal placed on the market across the EU or EEA either as a substance on its own or in a mixture – including in solders and alloys – above the relevant concentration thresholds must be classified and labelled, where required, in accordance with CLP, the Classification, Packaging and Labelling Regulation.

Where lead is supplied for industrial or professional use, REACH-compliant Safety Data Sheets must be provided, including exposure scenarios where the substance has been registered at 10 tonnes or more per year.

These requirements do not apply to articles such as architectural lead sheet, lead-based batteries, lead ammunition and articles fabricated from lead-containing alloys (e.g. brass pipes, taps etc).

Restrictions on supply to consumers

Lead metal is already restricted in specified uses as set out in Entry 63 of REACH Annex XVII. In light of the classification as a Category 1A reproductive toxicant, additional restrictions on the supply of lead metal to consumers will take effect under REACH on 1 March 2018.

Annex XVII lists the substances and groups of substances subject to REACH Restriction. Entries 28, 29 and 30 prohibit the supply to the general public of substances classified as carcinogenic, mutagenic or reproductive toxicant, Category 1A or 1B. The substances affected by these restrictions are listed in Appendices 1 to 6 of Annex XVII; lead metal is included in Appendix 5 by Regulation (EU) 2017/1510 from 1 March 2018.

From that date, supply to consumers is prohibited for lead metal as a substance, and in mixtures – including solders and other alloys – when the individual concentration is equal to or greater than 0.03% for mixtures containing lead metal powder, and 0.3% for mixtures containing lead metal in massive form.

This supply prohibition will not apply to architectural lead sheet, lead-based batteries, lead ammunition or other articles containing lead, unless they are otherwise restricted by Entry 63 of REACH Annex XVII or other legislation.

Lead producers should take all reasonable steps to remind their customers of this REACH restriction to ensure any affected products are not supplied to consumers after 1 March 2018.

Suppliers of lead as a substance and mixtures containing lead above the relevant concentration limits must ensure before placing those products on the market that the packaging is marked visibly, legibly and indelibly as: ‘Restricted to professional users’.

For more information, please refer to the Consortium’s updated “Lead Metal and the 9th ATP to CLP: Frequently Asked Questions”.