Joint statement by ICOMOS, ICOM and E.C.C.O on the plan to ban lead
The European Chemicals Agency's (ECHA) plan to include lead in the list of substances subject to authorisation (appendix XIV of the REACH Regulation) would have a major impact on a substantial part of the cultural heritage sector – and in particular on the art of stained glass and the restoration of Europe’s vast heritage of historic medieval to modern stained glass. Read the joint statement by ICOMOS, ICOM, E.C.C.O., ICOMOS-Corpus Vitrearum et ICOM-Glass.
The European Chemicals Agency (ECHA) is carrying out a public consultation with regards to the possible inclusion of lead in Appendix XIV (Authorization list) of the REACH Regulation, which aims to protect health and the environment. If lead is added to the list of substances requiring authorization for use or handling, this means its uses will be subject to the European authorization process (authorization to be requested either by the "downstream user" or by a user/supplier up the chain) and it will have to be demonstrated, among other things, that the risks for the uses are controlled. The objective of the authorization process is to replace hazardous substances. Formulating such authorization requests are time consuming and complex processes with no guarantee of a positive result.
Therefore ICOMOS, ICOM, E.C.C.O, ICOMOS-Corpus Vitrearum ISCCSG and ICOM-Glass are jointly issuing the attached statement strongly urging the ECHA and the European Commission to not ban the use of lead in the fabrication, conservation and restoration of stained glass and other cultural goods. There is a need for an official and permanent regulation that the art and production of stained glass in particular, but also the use and handling of lead in other cultural heritage sectors, is permanently removed from the list or given a permanent exemption from the EU Chemicals Regulation and all directives on hazardous substances (e.g. 2011/65/EU).
This statement will be sent to ECHA and the European Commission – as well as to other key actors in Europe – and uploaded on the consultation websites.
We encourage the ICOMOS members in Europe and all heritage professionals to also make submissions via the official ECHA consultation webpage and to encourage your networks to do likewise. For that purpose, you can find the model letter in English, which you can adapt as you wish or use parts of for the submission.
The deadline is however EXTREMELY SHORT : 2 May 2022!
You can also send the letter, among other, to:
- Mariya Gabriel, Commissioner for Innovation, Research, Culture, Education and Youth at email@example.com
- Your national cultural heritage authorities to alert them
- The European Commission representation in your country
- Your country’s EU representation in Brussels
ECHA official online consultation:
The Consultation on the draft recommendation for inclusion of lead in the Authorisation List – (EC Number: 231-100-4) includes two parts (you can switch the language at the top right hand of the page)
- A consultation on ECHAs draft recommendation
Paste main observations - in the field "Comments on uses (or categories of uses) that should be exempted, including reasons for that" and upload the full letter under Attachment IV.
- A call for information by the European Commission on the possible socio-economic consequences of the authorisation requirement
This comes in form of a questionnaire. You do not need to answer all the questions, only those that seem relevant and/or for which you have information to give. It is in English, but you can answer in any EU language. Once completed as is, or on your letterhead, you must upload it to that page. We suggest that you add the model letter we have prepared as an appendix to the questionnaire.
For more information on the process of including substances on the Authorization List, please visit the ECHA website : Recommendation for Inclusion in the Authorization List- ECHA (europa.eu).
Photo: Art by Hans Baldung Grien,1520 © Ivo Rauch