Space Sector calls on ECHA to withdraw its intention to propose lead metal for REACH authorisation – excessive amount of up to 200 or more applications estimated for lead-based soldering activities

On 28 April 2022 ASD-EUROSPACE – acting with the support of the European and national space agencies, and the European Defence Agency as observer – has sent joint contributions to the European Chemicals Agency (ECHA), as a response to ECHA’s public consultation on its Draft 11th Recommendation of Priority Substances for inclusion in the REACH Authorisation List (Annex XIV), including the substance lead (metal).

The contributions contain separate sets of comments to ECHA for its draft recommendation and the European Commission for its call for information on the possible socio-economic consequences of a (possible) authorisation requirement. As detailed in the comments, the Space Sector opposes this regulatory intention of ECHA for a number of reasons, in particular:

  • Lead is an essential element in a broad range of high reliability industrial applications requiring longevity in the European space industry, while alternatives are not known or not space-qualified.
  • Where possible and funding is available, substitution is already investigated; an important example is the ESCC Roadmap for Lead-free Transition in the European Space Sector of April 2020, which has resulted in a joint proposal for funding to the Commission in February 2022.
  • Space companies have been working with lead and have managed related risks for decades, based on already existing (e.g. workplace) legislation; risks are well known and considered as negligible.
  • Based on pertinent information gathered, the total number of applications for authorisation required only in the European Space Sector and only for lead-based soldering as the main space related use could go up to 200 or more (including subcontractors) – an excessive burden for such a small volume yet high-value user, but also for ECHA and the Commission for decision-making.
  • The impact of an authorisation requirement would affect the entire complex EU space systems’ supply chain. For SMEs, the financial and human investment would be even more important.
  • Non-EU operators would not have the authorisation burden, thereby creating a competitive disadvantage for their EU counterparts.
  • Requiring authorisation would also undermine the exclusion under the RoHS Directive (Article 2(4)(b)) for equipment designed to be sent into space.
  • In the current situation of legal revision (CSS REACH Revision, RoHS) the timeliness of this ECHA Annex XIV (draft) recommendation for lead metal is seriously questioned.

Therefore, the ECHA draft recommendation for lead should be withdrawn.

Note: The final decision to include substances recommended by ECHA in the REACH Authorisation List (Annex XIV) is with the European Commission. A “worst case” sunset date for lead metal could be in 2028.

Further information:


  • Pierre Lionnet, Research and Managing Director, ASD-EUROSPACE,, +33-(0)1 44 42 00 70