Because of political concerns on the use of PVC and PVC-additives and the call for a ban on PVC use of certain politicians in Sweden and Denmark, Bellona, a Norwegian environmental group, has written a letter to political parties.
Although we don't agree on several points, we give you here the original translated text of the letter. Where we don't agree is the phase out of phtalates, because these are abundant in nature, see our Chlorine and hormonal changes pages. Also in the case of the use of lead as a stabiliser in PVC. We don't think that is an environmental or health problem. See our PVC and additives pages. And even for short-living PVC, the costs of neutralising HCl in municipal waste incinerators are much lower than the higher prices, consumers will have to pay for the alternatives. HCl is not an environmental problem at all, compared with the 300-600 million tonnes of HCl, annualy released by the sea...



Oslo, March 18, 1996.

To Danmarks Sosialdemokratiske Parti

Proposal about ban on PVC

Re. proposal no. B 92 1995-96, 1. assembly.


A lot of ingredients which are used in PVC as plasticisers or stabilisers are documented to be toxic and/or 'hormone repeating' (synthetic oestrogens). These materials ought to be phased out as soon as possible.

Environmental problems from other plastics are very little investigated, because of focus on PVC. Danish Technology Institute has commisioned from the Environmental Agency in Denmark a series of scanning litterature studies of other plastics. These studies indicate a lot of problems linked to other plastics generally and illustrates the need for deeper comparative studies.

We will point at the need for studiing additives used in alternative plastics to PVC, like brominated fire retardants used in so called halogen free cable (which could emit brominated dioxins) and uranium, which is used as catalyst in ABS-plastic.

A general problem for all plastics is addition of heavy metals in form of pigments. European industry still uses environmental suspect pigments containing cadmium, chromium, copper and lead.
These heavy metals create environmental problems by disposure, both by use as stabiliser or pigment in the plastic.

Concerning outphasing of the polymeric material PVC we agree that this should be done for short lived products (< 1 year), because this will have a positive effect on the reduction of HCl in the waste disposal furnaces.

A wider outphasing must be seen in relation to the chlorine/alcali balance, otherwise there will be a risk for increased global environmental problems linked to chlorinated solvents and pesticides. 2/3 of chlorine produces in Sweden is used in PVC. This is a stable and environmental safe way of treating chlorine, compared to the alternatives (CFC, chlorinated solvents&pesticides).
Chlorine has to be handled because the consumption of alcali increases and will increase due to activities in the Al- and paperindustry. By technological improvements as removal of toxic ingredients and establishment of recycling, PVC can with advantage be used in longlasting products (pipes etc.). We refer to our fact sheet, which shows in more detail our views.

Metal based alternatives

Bellona agrees in the demand for phasing out lead and tin as additives in plastics. With our knowledge to the plastic industry we think however that January 1, 2000 is a too long time for the industry. It will not mean serious technical or economical problems for the industry to convert to other stabiliser systems than lead and tin within a relative short time limit, because environmental friendly systems already exist. Total outphasing of these products can be carried out 90% within 12 months and 100% within 24 months after decision has been taken. The time limit can therefore be much tighter. One has, however, to secure good routines for import control, so imported products get the same declarations as Danish produced goods.

There are used a lot more environmental- and health suspicious heavy metals in plastics, than what is said in the proposal. This is the case, both for additives for PVC and other plastics. We will mention pigments used in all thermoplastics, as:

Yellow (Barium, Titanium, Antimony, Nickel, Chromium, Zinc, Cadmium, Lead)
Green (Chromium, Cobalt, Titanium, Nickel, Zinc)
Blue (Cobalt, Chromium and others)
Brown (Chromium and others)
Red (Cadmium, Selenium, Lead, Chromium, Molybdenum and others)

In addition, heavy metals are used in plastics for other purposes. It will be too much to cover that item in this letter. As an example we will mention that Swedish Telia for environmental reasons wish to change their PVC cards with ABS. ABS can contain uranium, depending on the producer. Bellona anticipate that this was not known to Telia when substitution was launched. This illustrates the need for as much knowledge for the alternatives as we have for PVC today.

However, an offensive and realistic environmental policy for both Denmark and the EU will be a general ban on all suspicious heavy metals in all plastics, otherwise it will not have a positive environmental effect.

Organic additives

To Bellonas knowledge, there is only limited use of Bisphenol A in PVC. We have just one reference for such use. On the other side this material is used both as raw material and additive in a lot of alternative plastics to PVC.

Bisphenol A is the main component in this chapter, which is the most potent oestrogen imitator. This substance was already in 1936 discovered as endocrinic disturbing.
Bisphenol A is as separate additive in a lot of plastics, which have direct contact with food and humans, as in internal lacquering of Al-cans and in fillings for dental work. Bisphenol A should primarily phased out [in food applications], secondarily in products with human contact. In that case it are other plastics than PVC, which primarily should be phased out, or they have to be improved.

Concerning the phtalates DEHP, DINP, BBP and DBP, we wonder why it is just 4 of 20 commercial used phtalates, which should be phased out. To our knowledge from studies on different effects, it are not these 4 phtalates, which are worst concerning environment/health.
The uncertainity about the effects are great and Bellona thinks it's needed to initiate a better aimed research on this chemical group. This must be independent of potential law regulations against PVC, as long as phtalates are used for other purposes and because the level in the environment is occasionally high.
The Environment Agency's comparison document between PET and PVC reveals that there are also other plastic related sources for human exposure of phtalates.
PET, which is used all over Europe as mineral water bottles, is based on phtalates. Analyses taken on water and mineral water stored on PET show high values of phtalates in the drinking water. This bottle content can be health related suspicious and should therefore be investigated more closely. Already in 1993 the Environment Agency got this information.
The dimension and potential health risk for human exposure of phtalates from beverages in PET have not been satisfactory investigated. It has been focused on effects from phtalates in flooring and other products, which have never been in contact with foodstuff.

Chlorinated paraffins

Bellona agree in the aim for chlorinated paraffins. We cannot see any technical problems in changing the chlorinated paraffins in cutting oils as rapid as in plastics. In 1990 Bellona carried out a survey on the use in Norway and negotiated with the main users. As a result of that, the use of these materials is minimised in Norway.

Official buying regulations

Bellona will not recommend the Danish departments to implement buying regulations, which are not based on a good view of the market. So far it is only the environmental consequences on PVC, which has been investigated. Until one has a similar view on the alternatives, one should not push further. We know that some of the environmental problems, linked to PVC, are also the case for the substitutes and that the alternatives have other problems which are limited investigated. Until one get the cards on the table from the non-PVC industry, it is wise to held back regulations.
If the autorities phase out one product in a hurry and later on get something which is worse, it will hit back on the environmental reputation of the authorities.

Polyethylene versus polyvinylchloride

In the proposal it is concluded that PE has a lower impact on environment and health than PVC. The environmental impact these two plastics have, are partly comparable and also partly different. A direct comparison therefore is difficult, but possible. The problem is that so far there is not a single decent environmental report about PE, but hundreds on PVC.


Bellona agrees in the criticism of the progress to achieve recycling arangements. For all the thermoplastics we have the rule that the quality is falling with the number of recycling. This waste, which by nature has a low degradation ability and high mechanical stability, should be canalised to applications where these properties can be of advantage instead as of disadvantage.
It should, independent of PVC regulations, encourage the industry to do this. In particular it is actual to produce drainage pipes from waste plastics. Pipe products are needed in thousands of tons yearly and plastic waste can contribute to make cheap and long lasting pipes.

Dioxins and furans

It is said in the arguments for the decisionproposal that 'among these dioxins and furans, which are unavoidable linked to PVC'. This must be a clear misunderstanding. The prime source for dioxins has little to do with PVC.

The dioxin emissions from the burning of household waste and hospital waste, is first of all due to the technical standard of the burning ovens and not the chlorine content. The dioxin problems Denmark has with the waste handling equipment, can be fully solved by upgrading the burning technology.

Otherwise we will point at the fact that in the Nordic area, the dioxins come primarly from the metal melting industry. In Norway the main source is coming from the production of Mg, Fe and Ni, when in Sweden it comes from recycling of steel and Al-scrap.

Hydrochloric acid formation in waste burning

HCl formation in waste burning equipment is a considerable environmental and costproblem, especially with the standard on the Danish waste burning plants. This situation has to be improved. Generally is can be said that the authorities in Sweden and Norway have shown more interest for better waste treatment than burning. This has resulted in several material recycling plants, which have created jobs and have given better utilisation of the resources than burning.
For Denmark, which has short transport distances, and denser population, it should be a good base for increased recycling. With the present situation one has to combine increased material recycling with upgrading of the waste furnaces. Even with increased material recycling, there will be a lot of waste, which can and should be burned. For the Danish society it seems strange that the economical and labour related advantages with material recycling has not been of interest.


The decision proposal should be revised so all environmental suspicious plastic- and rubber additives and other environmental problems linked to plastics and rubber are eliminated in accordance with the goal of the Esbjerg-declaration.

With kind regards
Environmental foundation BELLONA

Rune Haaland


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