The European Chemicals Agency (ECHA) regularly assesses the substances on a Candidate List to decide which ones should be included in the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Authorisation List (Annex XIV) as a priority. Based on the prioritisation criteria, in February 2022, lead metal received priority and was proposed for inclusion in Annex XIV – further information available here. 

Given this decision could carry significant impacts for a range of solar photovoltaic technologies, PVthin has published a position paper on the matter. The paper explains that adding lead on the Authorisation List of ECHA will hinder innovation in solar photovoltaics (PV) but also other industries, affecting further deployment of PV in Europe. The position paper covers in detail the following key points:

• Including lead on the REACH Authorisation List would carry devastating impacts for current and future PV technologies, undermining efforts to scale PV manufacturing in Europe and deepening dependencies in strategic sectors.

• Lead is currently used for soldering in traditional PV panels. Its low melting point protects cells from cracking, increasing durability.

• Lead is also critical to the most innovative PV technologies, including Perovskites and Tandems, where it cannot be substituted. Due to their superior performance, the EU has allocated significant R&I funding.

• Reaching higher PV module conversion efficiencies through innovation will be critical to achieve global climate goals. Technologies like Perovskites and Tandems are at the forefront of such efforts.

• The EU is already in a position of extreme dependency when it comes to solar PV components. Chinese manufacturers supply roughly 89% of PV components globally.

• The REACH Authorisation does not apply to imported products. Including lead on the Authorisation List would prevent EU manufacturers from investing in Europe while having no impact on Chinese PV manufacturers who can continue to import PV components made using lead.

• PV sustainability, including chemical content considerations, is best regulated through a lifecycle approach weighing performance improvements with environmental and health impacts. 

• This is the approach used in ongoing efforts from the European Commission to roll out Ecodesign requirements for PV.

• Regulatory concerns around PV at end of life are currently regulated by the Waste from Electrical and Electronic Equipment (WEEE) Directive. 

Read and download the complete position paper here.