Miljøprojekt, 1134 – Evaluation of the Danish Statutory Order on Lead

Evaluation of the Danish Statutory Order on Lead

1 Introduction

Statutory Order no. 1012 of 13 November 2000 on Lead (the Lead Order) introduced general regulation of the use of lead in Denmark. The Statutory Order and the scope of the regulation are described in more detail in Chapter 2.

In a reply to the Danish Parliament's Environment and Regional Planning Committee in March 2003, the Minister for the Environment stated that "the Statutory Order on Lead should be allowed to work for another couple of years before an evaluation is made as to whether the Statutory Order should be revised" [MPU 2003a]. It has been pointed out that the exemption applying to use of lead for repairs, rebuilding of and extensions to houses should be included in such an evaluation [MPU 2003b].

Today, exemptions are granted for the use of lead in several product categories where technical or financial reasons have complicated the substitution of lead. Moreover, there is the general exemption for repairs, rebuilding of and extensions to houses. In this report, these uses have been evaluated to determine whether there is a need to adjust the Statutory Order in these areas.

It is likely that at least some of the product categories where the use of lead is allowed until further notice will have experienced further development of lead alternatives since the Statutory Order entered into force. Some of these uses are, thus, also in focus as regards the following EU regulation:

Directive 2002/95/EC on the restriction of the use of certain hazardous substances in electrical and electronic equipment – known as the "RoHS" Directive, which is implemented in Danish law by Statutory Order no. 1008 of 12/10/2004 on import and sale of electrical and electronic equipment containing lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE)
Directive 2000/537/EC on End-of-Life Vehicles, limiting the use of lead, cadmium, mercury and hexavalent chromium in vehicles.

Naturally, the uses covered by these Directives will still experience a development of lead alternatives. This development will probably also have positive effects on related areas.

This study will make a status as to the extent to which new knowledge has been published as a result of EU Directives and other initiatives that make it realistic to limit further the use of lead.

Chapter 2 presents the main points of the Statutory Order on Lead. The brief presentation of the Statutory Order will serve as a basis for the evaluation of the individual uses in the subsequent chapters.

The next chapters focus on uses for which dispensation has been granted from the Statutory Order, the general exemption for repairs, rebuilding of and extensions to houses, as well as other uses of lead as a chemical compound or metal exempted from regulation.

The final chapter, "Discussion and summary", presents the conclusions and recommendations given to highlight the possibilities of adjusting the regulation.