Recycled tyres: PAH limit of 20 mg/kg sought for playground/sporting products

Interested parties have until 19 August to comment on a European Chemicals Agency (ECHA) proposal to place restrictions upon the use of rubber granules made from end of life tyres (ELT) in certain products.

The proposal was originally submitted by the Netherlands due to concerns over the levels of eight carcinogenic polycyclic aromatic hydrocarbons (REACH-8 PAHs) within rubber granules. The ECHA’s Committee for Risk Assessment (RAC) and Committee for Socio-economic Analysis (SEAC) examined the pertinent information and respectively gave their support to the proposal on 7 and 14 June.

The problem the ECHA has with rubber granules is their use in playgrounds and synthetic turf, and the health risk this may pose. It notes that the PAH limits for rubber granules used in these products may be as much as 100 to 1,000 higher than REACH limits for articles supplied to the public.

Limits for PAHs within rubber granules and ELT mulches as set out by REACH (Annex XVII, entry 28) are currently either 100 or 1,000 mg/kg for each of the eight individual PAHs of concern. Noting that these limits are substantially higher than the limit value of 1 mg/kg for individual PAHs in articles supplied to the general public and the limit of 0.5 mg/kg for toys laid down in REACH (Annex XVII, entries 50.5 and 50.6), the ECHA, in cooperation with the Netherlands, drafted a restriction proposal within the framework of Reach Regulation article 69, paragraph 4.

With support from its RAC and SEAC, the ECHA proposes banning the sale of rubber granules or ELT mulches for use as infill material in synthetic turf pitches or in loose form on playgrounds and in sport applications if these materials contain more than 20 mg/kg PAHs. It notes that almost 99 per cent of ELT-derived granulate and mulch produced in the European Union already complies with this limit. The ECHA also believes 20 mg/kg to be a level that all ELT recyclers currently comply with or would be capable of complying with after investing in additional equipment.

Prior to proposing a limit of 20 mg/kg, the ECHA’s RAC and SEAC examined two proposed limits, 17 mg/kg and 6.5 mg/kg. They estimated the first would result in a loss of revenues of between 25 million and 50 million euros over a ten-year period and a “potential slight increase” in costs for sport pitches and public playgrounds. The estimated net revenue loss for the second proposed limit was 460 million to 950 million euros, plus the loss of some 400 jobs.