The ECHA (European Chemical Agency) has recommended that lead be included in the REACH (Registration, Evaluation, Authorisation, and Restriction of Chemicals) Regulations as part of an ongoing revision process. This would effectively ban its use in the production process for a number of products including musical instruments, with significant potential consequences. The concern from a UK perspective is that any changes to REACH adopted by the EU would simply be accepted into UK law as part of ongoing alignment with EU legislation to facilitate cross-border trading arrangements.
Woodwind and brass instruments use lead as an alloying agent, whilst piano makers utilise it in key weights. Lead has unique qualities which make it the best material for these uses, offering strength and longevity to musical instruments. One of the major challenges for manufacturers is that there is currently no suitable alternative that would maintain longevity, performance, and repairability in the same way.
“This has the potential to impact production processes and costs, and seems out of proportion to the minimal presence of lead in materials that will never come into contact with a player.”
William Ring, Howarth of London
The proposals are based on best practice for both environmental and health and safety reasons, which are clearly paramount, however, they do not take account of the very low levels of lead that are actually used in the production of musical instruments compared with other products or sectors.
The National Association of German Musical Instrument Manufacturers (BDMH) has already submitted evidence to the ECHA arguing the case for instrument makers to continue to be exempt from the legislation. The main points of this submission were as follows;
- The same accepted arguments that led to previous exemptions from the REACH directives are unchanged.
- The actual amount of lead used annually is very low (trace quantities) compared with most other industries that the legislation is targeting.
- Health hazards for musicians and instrument makers are demonstrably excluded.
- Hazards to the environment can be ruled out since cycles of reuse or recycling exist.
- Lead is indispensable for musical instrument making, due to its unique technical characteristics.
- If its use is prohibited both the acoustic and build quality of instruments will decline. The lifespan of instruments will almost certainly decrease, as they will be very difficult or impossible to repair. This in itself will have environmental consequences.
- In addition to the manufacture of musical instruments, the trade in musical instruments and accessories will subsequently also be affected, both domestically and abroad.
- The cultural damage would be immense.
There are two things the MIA is doing about this; firstly by raising awareness within the industry, and secondly by lobbying on this matter to ensure the UK has a stance on preventing this damage to the MI Sector.
We are currently collecting evidence and engaging with interested partners for support, and will be writing to the Government in due course to begin that process. If you feel your commercial activities will be impacted by this development please get in touch with Matt and support our work on this important matter.
