VinylPlus Healthcare, together with PVC Forum (Sweden) and PVC-Informationsrådet (Denmark), has submitted a joint consultation response to the Nordic Swan Ecolabel draft criteria for medical devices in plastic or silicone (098).
The response welcomes the ambition to promote environmentally and health-responsible material choices in the healthcare sector. At the same time, it raises fundamental concerns regarding the categorical exclusion of polyvinyl chloride (PVC or vinyl) in the current draft criteria without a documented, holistic and risk-based assessment of alternative materials.
Call for Evidence-Based and Technology-Neutral Criteria
The submission highlights the importance of ensuring that ecolabel criteria:
- are based on comparable, life-cycle assessments of materials
- are aligned with existing EU regulatory evaluations, including the European Chemicals Agency (ECHA)’s 2023 assessment of PVC
- apply consistent requirements across all polymers to avoid regrettable substitution
- integrate circularity and economic proportionality as core elements
The response underlines that PVC in medical devices is already subject to strict EU legislation, including REACH and the Medical Device Regulation (MDR), and that classified phthalates have largely been substituted in the European market.
Circularity and Practical Healthcare Realities
The joint submission also stresses that circularity should play a central role in material evaluation. Currently, the only documented and operational post-use recycling initiatives for medical devices in Europe are PVC-based and developed within the VinylPlus Healthcare framework.
Excluding a material already integrated into functioning recycling schemes, while allowing alternatives without documented circularity pathways, risks undermining the environmental ambition of the criteria.
Supporting Credible and Proportionate Ecolabelling
As an officially recognised ecolabel used in public procurement and market communication, Nordic Swan carries a responsibility to ensure proportional, evidence-based and scientifically robust criteria.
VinylPlus Healthcare and its co-signatories encourage continued dialogue to support criteria that safeguard patient safety, environmental performance and well-functioning healthcare systems across the Nordic region.
