Restricting PAHs in granules and mulches
In July 2018, the Dutch authority RIVM proposed a restriction to limit the concentration of eight PAHs in granules or mulches used as infill material in synthetic turf pitches or in loose form for use in sports applications and on playgrounds. The legal concentration limits in force at the time of the proposal were 100 mg/kg for two of the PAHs (BaP and DBAhA) and 1 000 mg/kg for the other six (BeP, BaA, CHR, BbFA, BjFA, BkFA). These limits were considered by RIVM to be too high to ensure the safety of people, and especially children, playing on sports pitches and playgrounds.
PAHs are known constituents of both extender oils and carbon black used in the manufacture of vehicle tyres. They are known to cause cancer. Animal model studies link the group of chemicals to skin, lung, bladder, liver and stomach cancers. PAHs have also been linked with heart disease and poor foetal development.
The restriction assessed the risks from eight PAHs to professional footballers, children playing on the pitches, and workers involved in installing and maintaining the pitches and playgrounds.
The Dutch authorities recommended to lower the combined concentration limit for the eight PAHs to 17 mg/kg. The aim was to ensure that exposure to the PAHs remains at a low level also in the future and that the use of infill from imported recycled tyres is also regulated.
ECHA’s Committees for Risk Assessment (RAC) and Socio-Economic Analysis (SEAC) started their evaluation of the proposal in September 2018. A consultation on the proposal ran from September 2018 to March 2019. Subsequently, there was a consultation on the SEAC draft final opinion from June to August 2019.
Committee opinions
The consolidated opinion of RAC and SEAC was sent to the European Commission at the end of 2019. RAC evaluated the risks of PAHs to people’s health. SEAC evaluated the benefits of the proposal to people’s health and the associated costs and other socio-economic impacts.
Both committees agreed that – with a few modifications – a restriction proposal would be the most appropriate means to ensure that the cancer risk from PAH exposure remains at a low level for those playing on artificial sports pitches or playgrounds that use rubber infill or mulches. The opinion proposed a concentration limit of the eight PAHs of 20 mg/kg.
Decision by the European Commission and EU Member States
The restriction was supported by EU Member States in December 2020 and adopted by the Commission in July 2021. It prohibits the placing on the market and use of granules and mulches as infill if they contain more than 20 mg/kg of the sum of the eight PAHs. Granules or mulches placed on the market also have to be batch labelled to ensure safe use.
The new rules apply in the EU/EEA from 10 August 2022. It will make playing on artificial sports pitches and playgrounds safer and may help to ease social concerns and worries over playing on artificial sports pitches and playgrounds. The restriction will not affect existing fields immediately but will ensure that any infill material used for refilling the fields is below the new limit.
Restricting intentional uses of microplastics
In January 2019, ECHA proposed a
wide-ranging restriction on microplastics in products placed on the EU/EEA market to avoid or reduce their release to the environment. This restriction proposes to address the spreading of infill material from artificial pitches.
The Commission
adopted the restriction on 25 September 2023. The first measures, for example the ban on loose glitter and microbeads, started applying on 17 October 2023, when the restriction entered into force. In other cases, the sales ban will apply after a longer period to give affected stakeholders the time to develop and switch to alternatives. For granular infill material used on artificial sport surfaces, the ban starts to
apply from 17 October 2031. This transition period was granted to give pitch owners and managers time to switch to alternatives and allow for most existing sport pitches to reach their end of life.
Additional study on chemicals in infill
In May 2021, ECHA published a
follow-up study on substances (other than PAHs) in plastic and rubber granules and mulches used as infill on artificial pitches. It identified over 300 chemicals that could potentially be found in the infill material and created criteria to prioritise those that potentially pose the greatest concern.
Based on this, ECHA recommended that further assessments should be carried out on certain chemicals that could be harmful to people or the environment. These chemicals are:
- Cobalt and zinc- with potential risk to people’s health; and
- Cadmium, cobalt, copper, lead, zinc, 4-tert-octylphenol, 4,4´-isopropylidene diphenol (BPA), bis(2-ethylhexyl)phthalate (DEHP), benzyl butyl phthalate (BBP) and benzothiazole-2-thiol – with potential risk to the environment.
The risks of PAHs to the environment also need to be examined in any future assessments. ECHA suggests that the refinement of risk the conclusions is done within the context of preparing a REACH restriction proposal.
Further investigation on PAHs in granules and mulches
The European Commission requested ECHA in January 2023 to assess the risks to children from PAHs in granules and mulches in playgrounds and other domestic applications such as gardening and landscaping. An initial screening assessment of risks was published in June 2023.
