Metallic Lead targeted by REACH – Joint response by dedicated Space Task Force

With 31 Lead compounds already included in the REACH Candidate List for Authorisation, the Swedish Chemicals Agency (KEMI) has now also proposed Metallic Lead for that List. Lead is classified as toxic for reproduction (Cat. 1A) and is still used widely in large volumes today. The 45-day public consultation on the Swedish proposal by the European Chemicals Agency (ECHA) closed on 23 April 2018.

In the European Space Sector Lead has been used for decades for high reliability applications requiring longevity. Main mission-critical uses without technically viable alternatives today include Tin/Lead solder alloys for Electrical and Electronic Equipment (EEE); Indium/Lead solder on thick gold; some alloys (e.g. Lead containing copper or brass); coatings for long-life systems; and pyrotechnical devices.

Against this background the Materials and Processes Technology Board of the European Space Components Coordination (ESCC MPTB) initiated a dedicated Lead metal REACH Space Task Force (”LTF”) on 12 March 2018. The LTF is open to all companies and agencies in the European Space Sector and aims to cover all relevant uses of Lead metal for space applications. Current Task Force participants include:

  • Companies: AIRBUS DEFENCE AND SPACE, ARIANEGROUP, ESR TECHNOLOGY, RUAG SPACE, TESAT SPACECOM, THALES ALENIA SPACE
  • Space agencies: CNES, DLR, ESA
  • EUROSPACE is acting as Secretariat and REACHLaw Ltd. as consultant.

The first objective of the LTF is to ensure the most appropriate regulatory treatment for space applications of Metallic Lead under REACH by

  • Preparing joint sector-level input to ECHA consultations on regulatory proposals and
  • Coordinating activities with other affected industry groups.

On 20 April 2018 EUROSPACE has submitted the LTF’s joint response to the public consultation on Metallic Lead to the ECHA. The response details the uses of Lead in the European space industry, outlines the situation on alternatives and describes impacts and risks of possible candidate listing and authorisation. The paper concludes that candidate listing and possible future inclusion in the authorisation list would not be an appropriate risk management option for Lead, also having regard to the explicit exclusion for EEE designed to be sent into space under the RoHS Directive 2011/65/EU.

The LTF will keep on following the REACH regulatory developments concerning Metallic Lead, and take action as necessary to defend the continued use as far as required.

Please contact Pierre Lionnet at EUROSPACE for information.

The joint response to ECHA of 20 April 2018 is available here.