The use of lead sulfochromate yellow and lead chromate molybdate sulfate red in paints
HMG (& many other paint manufacturers) have used Lead sulfochromate yellow (Pigment Yellow 34) and lead chromate molybdate sulfate red (Pigment Red 104) in some paints for many years. The introduction of the REACH regulations within the EU raised doubts regarding their continued use. Several years ago, HMG Paints Limited took the decision to remove these pigments from our water based paints and from our powder coatings. Our solvent based paints that contain these pigments are designated as ‘contains lead’ on the HS label attached to all packaging. HMG also embarked on a full development programme and already offer a comprehensive range of solvent based products that are available as ‘lead-free’.
Recently, our supplier DCC Maastricht BV, representing Dominion Colour Corporation (DCC) has been granted authorisation under REACH that allows these pigments to be placed on the market and for continued use in some paints for certain purposes. The authorisation is subject to re-assessment over a given time and places certain obligations on the downstream users of the materials, which must be notified to the European Chemical Agency (ECHA).
Authorisation allows the continued use of these pigments; however their use in paint products is restricted to three distinctly defined uses (see below) for industrial and professional users only.
Use 1 Use: distribution and mixing of pigment powder in an industrial environment into solvent-based paints for non-consumer use
Use 2 Use: industrial application of paints on metal surfaces (such as machines vehicles, structures, signs, road furniture, coil coating, etc.)
Use 3 Use: professional, non-consumer application of paints on metal surfaces (such as machines, vehicles, structures, signs, road furniture, etc.) or as road marking
Authorisation for restricted uses also requires additional obligations for users of products containing these pigments and obligations vary depending whether you are classed under REACH as a distributor or a downstream user (DU), the majority of HMG customers would be considered as downstream users as most customers will handle the product by mixing, transferring or re-packing.
HMG Paints Limited have worked with their pigment supplier (DCC Maastricht BV) to produce the required support documents (eSDS and notification templates) and guidance to help our customers with the authorisation process, links to these resources can be found below:
HMG Information Letter: Download PDF
HMG Distributor Checklist: Download PDF
HMG Downstream User Checklist: Download PDF
Authorised Coatings End User Pyramids: Download PDF
Example of Analysis of Alternatives for PY34 & PR104 End Uses & Alternatives for Coatings: Download PDF
HMG Guidance for ECHA Registration REACH IT: Download PDF
BCF Information Note Lead Chromates: Download PDF
PR104 Use 1 Exposure Scenario: Download PDF
PR104 Use 1 Verification Notification Template: Download PDF
PR104 Use 2 Exposure Scenario: Download PDF
PR104 Use 2 Verification Notification Template: Download PDF
PR104 Use 3 Exposure Scenario: Download PDF
PY34 & PR104 End Uses and Alternatives Template: Download PDF
PY34 Use 1 Exposure Scenario: Download PDF
PY34 Use 1 Verification Notification Template: Download PDF
PY34 Use 2 Exposure Scenario: Download PDF
PY34 Use 2 Verification Notification Template: Download PDF
PY34 Use 3 Exposure Scenario: Download PDF
PY34 Use 3 Verification Notification Template: Download PDF