IEC 62474 DSL Updated to Align with “Article” Interpretation

The IEC 62474 Declarable Substance List (DSL) was updated (D11.00) on March 28, 2016 to reflect the September 2015 European Court of Justice (ECJ) interpretation of the term “article”. The ECJ ruling is important for OEMS and suppliers in determining whether a REACH Candidate List SVHC is above the 0.1 mass% threshold that triggers communication and notification obligations under the EU REACH regulation. A summary of the ECJ ruling is available from the blog post EU Judgment – SVHC Reporting Required for First Article.

The 71 REACH SVHCs entries in the DSL have had their reporting threshold revised to “0.1 mass% of article” to indicate that the threshold refers to an individual article.

In developing a solution to align the DSL with the ECJ ruling, the IEC 62474 validation team (VT) considered the possibility of using the term “product part” to represent an article; however, a “product part” in a material declaration can be used to represent any of several levels of subassemblies and components in a EEE product. Therefore, in many situations, it may not always be a match for the REACH definition of article.

The VT also discussed the possibility of including some type of guidance to assist manufacturer in using the threshold in the context of electrical and electronic products. However, given that guidance on the practical interpretation of “article” is still the subject of intense discussion by regulators, politicians industry and other stakeholders for the next release of the European Chemical Agency (ECHA) guidance document on substances in articles, it wouldn’t be appropriate for the VT to try to second guess the conclusion of this work.  Once ECHA publishes its guidance document with examples, the IEC 62474 DSL may be revised again to support the guidance.

Reporting Levels

With the ECJ ruling addressed, the new “ReportingLevel” field, which was recently added to the database, was populated.  The ReportingLevel field is intended to simplify for users the interpretation of the more complex reporting thresholds. Some of the reporting thresholds are difficult to interpret because of how they are written in the regulation. For example, some thresholds refer to a part, but the actual intention from the regulation is material.

The ReportingLevel for a  given DSL entry indicates one of four possible values: Product, Product Part, Article or Material.

Changes to Declarable Substance Groups

There were a couple of additional minor DSL changes.

The scope of the substance group “Polychlorinated Naphthalenes (PCNs)” was expanded to include all such substances with 1 or more chlorine atoms Previously only substances with  more than 3 chlorine atoms were consider to be included in the group. The change is based on the additional requirements of the EU POP regulation.

For consistency in substance naming, the substance group  “4-Nonylphenol, branched and linear, ethoxylated [substances with a linear and/or branched alkyl chain with a carbon number of 9 covalently bound in position 4 to phenol, ethoxylated covering UVCB- and well-defined substances, polymers and homologues, which include any of the individual isomers and/or combinations thereof]” was abbreviated to “4-Nonylphenol, branched and linear, ethoxylated” to align with the IEC 62474 substance naming convention. The portion of the  name that appears in square brackets is not actually part of the chemical name but rather a description of the substance group.  This description has been moved to the comment field in the DSL entry.

Reference Substances

Given the expanded scope of the Polychlorinated Naphthalenes (PCNs) substance group, a large number of additional references have been added in place of the generic reference substance “Other polychlorinated Naphthalenes”. The added reference substances are listed in Table 1 below.

Four additional reference substances have been list for the substance group “4-Nonylphenol, branched and linear, ethoxylated”. The new entries are shown in Table 2.

 Material Classes and the XML Schema

 No changes were made to the material classes or the XML Schema during this update.

Table 1: Reference Substances Added for Polychlorinated Naphthalenes (PCNs)

Substance GroupSpecific SubstanceCAS number
Polychlorinated Naphthalenes (PCNs)1-Chloronaphthalene90-13-1
Polychlorinated Naphthalenes (PCNs)2-Chloronaphthalene91-58-7
Polychlorinated Naphthalenes (PCNs)1,5-Dichloronaphthalene1825-30-5
Polychlorinated Naphthalenes (PCNs)1,4-Dichloronaphthalene1825-31-6
Polychlorinated Naphthalenes (PCNs)1,2-Dichloronaphthalene2050-69-3
Polychlorinated Naphthalenes (PCNs)1,6-Dichloronaphthalene2050-72-8
Polychlorinated Naphthalenes (PCNs)1,7-Dichloronaphthalene2050-73-9
Polychlorinated Naphthalenes (PCNs)1,8-Dichloronaphthalene2050-74-0
Polychlorinated Naphthalenes (PCNs)2,3-Dichloronaphthalene2050-75-1
Polychlorinated Naphthalenes (PCNs)2,6-Dichloronaphthalene2065-70-5
Polychlorinated Naphthalenes (PCNs)1,3-Dichloronaphthalene2198-75-6
Polychlorinated Naphthalenes (PCNs)2,7-Dichloronaphthalene2198-77-8
Polychlorinated Naphthalenes (PCNs)Chloronaphthalene25586-43-0
Polychlorinated Naphthalenes (PCNs)Dichloronaphthalene28699-88-9
Polychlorinated Naphthalenes (PCNs)Pentachloronaphthalene1321-64-8
Polychlorinated Naphthalenes (PCNs)Trichloronaphthalene1321-65-9
Polychlorinated Naphthalenes (PCNs)Hexachloronaphthalene1335-87-1
Polychlorinated Naphthalenes (PCNs)Tetrachloronaphthalene1335-88-2
Polychlorinated Naphthalenes (PCNs)Perchloronaphthalene 2234-13-1
Polychlorinated Naphthalenes (PCNs)1,4,6-Trichloronaphthalene2437-54-9
Polychlorinated Naphthalenes (PCNs)1,4,5-Trichloronaphthalene2437-55-0
Polychlorinated Naphthalenes (PCNs)1,4,5,8-Tetrachloronaphthalene3432-57-3
Polychlorinated Naphthalenes (PCNs)1,2,4,8-Tetrachloronaphthalene6529-87-9
Polychlorinated Naphthalenes (PCNs)1,2,4,5-Tetrachloronaphthalene6733-54-6
Polychlorinated Naphthalenes (PCNs)1,2,3,6,7,8-Hexachloronaphthalene17062-87-2
Polychlorinated Naphthalenes (PCNs)1,2,3,4-Tetrachloronaphthalene20020-02-4
Polychlorinated Naphthalenes (PCNs)1,3,5,8-Tetrachloronaphthalene31604-28-1
Polychlorinated Naphthalenes (PCNs)Heptachloronaphthalene32241-08-0
Polychlorinated Naphthalenes (PCNs)2,3,6,7-Tetrachloronaphthalene34588-40-4
Polychlorinated Naphthalenes (PCNs)1,2,4-Trichloronaphthalene50402-51-2
Polychlorinated Naphthalenes (PCNs)1,2,3-Trichloronaphthalene50402-52-3
Polychlorinated Naphthalenes (PCNs)1,3,5-Trichloronaphthalene51570-43-5
Polychlorinated Naphthalenes (PCNs)1,2,6-Trichloronaphthalene51570-44-6
Polychlorinated Naphthalenes (PCNs)1,2,4,6-Tetrachloronaphthalene51570-45-7
Polychlorinated Naphthalenes (PCNs)1,2,3,5-Tetrachloronaphthalene53555-63-8
Polychlorinated Naphthalenes (PCNs)1,3,5,7-Tetrachloronaphthalene53555-64-9
Polychlorinated Naphthalenes (PCNs)1,2,3,5,7-Pentachloronaphthalene53555-65-0
Polychlorinated Naphthalenes (PCNs)1,2,5-Trichloronaphthalene55720-33-7
Polychlorinated Naphthalenes (PCNs)1,2,7-Trichloronaphthalene55720-34-8
Polychlorinated Naphthalenes (PCNs)1,2,8-Trichloronaphthalene55720-35-9
Polychlorinated Naphthalenes (PCNs)1,3,6-Trichloronaphthalene55720-36-0
Polychlorinated Naphthalenes (PCNs)1,3,7-Trichloronaphthalene55720-37-1
Polychlorinated Naphthalenes (PCNs)1,3,8-Trichloronaphthalene55720-38-2
Polychlorinated Naphthalenes (PCNs)1,6,7-Trichloronaphthalene55720-39-3
Polychlorinated Naphthalenes (PCNs)2,3,6-Trichloronaphthalene55720-40-6
Polychlorinated Naphthalenes (PCNs)1,2,3,7-Tetrachloronaphthalene55720-41-7
Polychlorinated Naphthalenes (PCNs)1,3,6,7-Tetrachloronaphthalene55720-42-8
Polychlorinated Naphthalenes (PCNs)1,4,6,7-Tetrachloronaphthalene55720-43-9
Polychlorinated Naphthalenes (PCNs)1,2,3,4,5,6,7-Heptachloronaphthalene58863-14-2
Polychlorinated Naphthalenes (PCNs)1,2,3,4,5,6,8-Heptachloronaphthalene58863-15-3
Polychlorinated Naphthalenes (PCNs)1,2,3,4,5,6-Hexachloronaphthalene58877-88-6
Polychlorinated Naphthalenes (PCNs)1,2,4,7-Tetrachloronaphthalene67922-21-8
Polychlorinated Naphthalenes (PCNs)1,2,5,6-Tetrachloronaphthalene67922-22-9
Polychlorinated Naphthalenes (PCNs)1,2,5,7-Tetrachloronaphthalene67922-23-0
Polychlorinated Naphthalenes (PCNs)1,2,6,8-Tetrachloronaphthalene67922-24-1
Polychlorinated Naphthalenes (PCNs)1,2,3,4,5-Pentachloronaphthalene67922-25-2
Polychlorinated Naphthalenes (PCNs)1,2,3,4,6-Pentachloronaphthalene67922-26-3
Polychlorinated Naphthalenes (PCNs)1,2,3,4,5,7-Hexachloronaphthalene67922-27-4
Polychlorinated Naphthalenes (PCNs)1,2,4,5,6,8-Hexachloronaphthalene90948-28-0
Polychlorinated Naphthalenes (PCNs)1,2,4,5,7,8-Hexachloronaphthalene103426-92-2
Polychlorinated Naphthalenes (PCNs)1,2,3,4,5,8-Hexachloronaphthalene103426-93-3
Polychlorinated Naphthalenes (PCNs)1,2,3,5,7,8-Hexachloronaphthalene103426-94-4
Polychlorinated Naphthalenes (PCNs)1,2,3,5,6,8-Hexachloronaphthalene103426-95-5
Polychlorinated Naphthalenes (PCNs)1,2,3,4,6,7-Hexachloronaphthalene103426-96-6
Polychlorinated Naphthalenes (PCNs)1,2,3,5,6,7-Hexachloronaphthalene103426-97-7
Polychlorinated Naphthalenes (PCNs)1,2,3,6-Tetrachloronaphthalene149864-78-8
Polychlorinated Naphthalenes (PCNs)1,2,6,7-Tetrachloronaphthalene149864-79-9
Polychlorinated Naphthalenes (PCNs)1,2,5,8-Tetrachloronaphthalene149864-80-2
Polychlorinated Naphthalenes (PCNs)1,2,3,8-Tetrachloronaphthalene149864-81-3
Polychlorinated Naphthalenes (PCNs)1,2,7,8-Tetrachloronaphthalene149864-82-4
Polychlorinated Naphthalenes (PCNs)1,2,3,7,8-Pentachloronaphthalene150205-21-3
Polychlorinated Naphthalenes (PCNs)1,3,6,8-Tetrachloronaphthalene150224-15-0
Polychlorinated Naphthalenes (PCNs)1,2,3,6,7-Pentachloronaphthalene150224-16-1
Polychlorinated Naphthalenes (PCNs)1,2,4,6,7-Pentachloronaphthalene150224-17-2
Polychlorinated Naphthalenes (PCNs)1,2,3,5,6-Pentachloronaphthalene150224-18-3
Polychlorinated Naphthalenes (PCNs)1,2,4,5,7-Pentachloronaphthalene150224-19-4
Polychlorinated Naphthalenes (PCNs)1,2,4,5,6-Pentachloronaphthalene150224-20-7
Polychlorinated Naphthalenes (PCNs)1,2,4,7,8-Pentachloronaphthalene150224-21-8
Polychlorinated Naphthalenes (PCNs)1,2,4,6,8-Pentachloronaphthalene150224-22-9
Polychlorinated Naphthalenes (PCNs)1,2,3,6,8-Pentachloronaphthalene150224-23-0
Polychlorinated Naphthalenes (PCNs)1,2,3,5,8-Pentachloronaphthalene150224-24-1
Polychlorinated Naphthalenes (PCNs)1,2,4,5,8-Pentachloronaphthalene150224-25-2

Table 2: Newly added reference substances for 4-Nonylphenol, branched and linear, ethoxylated

Substance GroupSpecific SubstanceCAS number
4-Nonylphenol, branched and linear, ethoxylatedEthanol, 2-(4-nonylphenoxy)-104-35-8
4-Nonylphenol, branched and linear, ethoxylatedIsononylphenol ethoxylate37205-87-1
4-Nonylphenol, branched and linear, ethoxylatedPoly(oxy-1,2-ethanediyl), alpha-(4-nonylphenyl)-omega-hydroxy-, branched127087-87-0
4-Nonylphenol, branched and linear, ethoxylated4-tert-Nonylphenol diethoxylate156609-10-8

IEC 62474 DSL Update – Version D10.00

Version D10.00 of the IEC 62474 Declarable Substance List (DSL) and the Reference Substance List (RSL) were released on December 17, 2015. The substance lists are used globally by EEE manufacturers, suppliers, and IT solution providers as a common list of substances and substance groups that are declared throughout the supply chain. Declaration of the substances are important for downstream manufacturers to determine conformity of EEE products to substance regulations around the world and to perform due diligence in conformity assessment.

The update includes:

  • four of five substances from the December 17, 2015 SVHC additions to the EU REACH Candidate List and
  • changes in the reporting threshold of the four phthalate substances that were added to the EU RoHS Directive earlier this year.

The IEC 62474 data exchange format (XML schema and developer’s table) was not updated during this maintenance cycle.  The database update is the final step in maintenance cycle (MC-2015-02) which was started in September.

Background

The IEC 62474 DSL is an internationally recognized and harmonized list of substances and substance groups that are regulated and may be constituents of electrical and electronic products and systems. Electrical and electronic manufacturers and suppliers use the DSL in their design and supply chain management operations to specify and control substances of concern. The list is typically updated as needed based on regulatory changes. For additional information about IEC 62474, see the article About IEC 62474. The IEC 62474 database is available online (free of charge); the standard itself which specifies the material declaration requirements and rules may be purchased in the same manner as any other IEC standard — from the IEC webstore or a reseller.

Additions to the Declarable Substance List (DSL)

Additions and technical modifications to the DSL were driven by two regulations: EU REACH and EU RoHS. The new entries are listed in the table below

New and Modified Substance Entries in the DSL - D10.00

SubstanceCAS numberTypical ApplicationsReporting ThresholdRegulation
Bis (2-ethylhexyl)phthalate (DEHP)117-81-7Plasticizer, dye, pigment, paint, ink, adhesive, lubricant0.1 mass% in homogenous materialEU RoHS
Dibutyl phthalate (DBP)84-74-2Plasticizer, dye, pigment, paint, ink, adhesive, lubricant0.1 mass% in homogenous materialEU RoHS
Benzyl butyl phthalate (BBP)85-68-7Plasticizer, dye, pigment, paint, ink, adhesive, lubricant0.1 mass% in homogenous materialEU RoHS
Diisobutyl phthalate84-69-5Plasticizer, dye, pigment, paint, ink, adhesive, lubricant0.1 mass% in homogenous materialEU RoHS
1,3-propanesultone1120-71-4Electrolyte fluid of rechargeable lithium ion batteries 0.1 mass%REACH Candidate List
2,4-di-tert-butyl-6-(5-chlorobenzotriazol-2-yl)phenol (UV-327)3864-99-1UV stabilizer0.1 mass%REACH Candidate List
2-(2H-benzotriazol-2-yl)-4-(tert-butyl)-6-(sec-butyl)phenol (UV-350)36437-37-3UV stabilizer0.1 mass%REACH Candidate List
Perfluorononan-1-oic-acid and its sodium and ammonium salts375-95-1, 21049-39-8, 4149-60-4Surfactant in the production of the fluoropolymer polyvinylidene fluoride (PVDF)0.1 mass%REACH Candidate List

EU REACH Candidate List

Four of the five SVHCs added to the REACH Candidate List on December 17, 2015 were identified as being possible constituents of EEE products and are therefore included in the DSL. The validation team did not find any evidence that the other SVHC added to the Candidate List would exist in EEE above the reporting threshold.

Note: The reporting threshold for the new REACH SVHC substance entries is listed as “0.1 mass%” in the same manner as the other REACH SVHCs listed in the DSL; however, the IEC 62474 validation team is working on a systemic change to the reporting thresholds to take into account the European Court of Justice ruling in September with regard to the interpretation of article.

EU RoHS

The four Phthalates DEHP, DBP, BBP, and DIBP were added into the EU RoHS Directive with the restrictions taking effect starting on July 22, 2019. Although the restriction date is several years out, some of these phthalates are pervasively used in EEE and will take significant time and effort to eliminate. Adding these substances to the IEC 62474 DSL now is necessary to help manufacturers identify the use of these substances throughout their supply chain.

The original six RoHS substance entries were also updated to reflect the recast Directive 2011/65/EU instead of the original 2002/95/EC.   This is a minor editorial change.

New data field for Reporting Level

A number of new features were added recently to the IEC 62474 database. This includes a new data field has been added to all DSL entries for “Reporting Level”. This field is currently blank, but will used in the near future to provide additional information to help users interpret the reporting threshold. You can find additional information on the new features added by the IEC IT team in an earlier posting.

Changes to the Reference Substance List (RSL)

Two minor changes were made to the Reference Substance List (RSL).

  • The CAS number 31119-53-6 was added to the entry for Cadmium sulfate
  • The CAS number 7789-12-0 was added to the entry for Sodium dichromate

 Material Classes

There were no changes to the Material Classes.

 Additional Information

If anyone is aware of errors or omissions in the database (e.g. a regulated substances that is not included in the DSL but has potential EEE applications) or a regulatory reference that is out of date, please send an email to ECD Compliance and we will review and address with the  IEC 62474 validation team.

For further information on IEC 62474 or for support on your substance management program, please contact ECD Compliance.

IEC 62474 Database Gets Some New Features

On December 14, 2015, the IEC Central Office rolled out some new features in the IEC 62474 database.  The features improve the usability of the database and also provide some new features to support the validation team that maintains the database.

The most significant changes relevant to users include:

  • A new data field for “Reporting Level” has been added to each Declarable Substance List (DSL) entry (more detail on this is provided below)
  • The Export button for the reference substance (RSL) list has been moved further left to make it more visible when a user has a narrow browser window.
  • Users may now export the RSL as an XML file
  • The header message at the top of the browser window that indicates that database status and version now includes a scroll bar to allow users to review the entire message when using a narrow browser window
  • The substance drop-down has been narrowed by showing only the first 30 characters and last 20 characters of a substance or substance group name. The drop-down used to be over 200 characters wide due to some very long substance names. Narrowing the drop-down list makes substance selection more practical. When a specific substance is selected, the entire substance name appears in light grey just below the drop-down box.

The New “Reporting Level” field

Some of the reporting thresholds are quite complex and it’s not always easy to determine whether the reporting threshold applies to a material, a product part, or the entire product. The intention of the “Reporting Level” field is to clearly indicate the basis for the reporting threshold (i.e. what should be used as the denominator when calculating the mass percent for comparing to the reporting threshold). The “reporting Level data fields are currently left blank but will be filled in once the IEC 62474 validation team decides how to address the impact of the recent European Court of Justice ruling on REACH interpretation of article.

Contact ECD Compliance for information on how we can assist your business with setting up a material declaration system and conformity assessment procedures.

IEC 62474 declarable substance list update planned for late December 2015

The next update to the IEC 62474 declarable substances list is being planned for mid or late December 2015. The actual release date will be dependent on when ECHA updates the REACH Candidate List of SVHCs. If all of the change requests currently undergoing voting are approved, the following changes are expected:

  • Five of the seven SVHCs proposed by ECHA for the REACH Candidate List are expected to be added.
  • The reporting threshold for the four phthalate substances that were added to the EU RoHS Directive will be updated to 0.1 mass% in homogeneous materials.
  • Other editorial changes to some of the DSL entries and the reference substances

 

IEC 62474 Declarable Substance List Update – Version D9.00

The IEC 62474 online database was updated on July 15, 2015. Version D9.00 of the Declarable Substance List (DSL) and the Reference Substance List (RSL) are now available for use by EEE manufacturers, suppliers, and IT solution providers. The data exchange format (XML schema and developer’s table) is now version X6.01 (this is a minor editorial revision from X6.00). The database update is the final step in maintenance cycle (MC-2015-01) which was started earlier this year.

The IEC 62474 DSL is an internationally recognized and harmonized list of substances and substance groups that are regulated and may be constituents of electrical and electronic products and systems. Electrical and electronic manufacturers and suppliers use the DSL in their design and supply chain management operations to specify and control substances of concern. The list is typically updated as needed based on regulatory changes. For additional information about IEC 62474, see the article About IEC 62474. The IEC 62474 database is available online (free of charge); the standard itself which specifies the material declaration requirements and rules may be purchased in the same manner as any other IEC standard — from the IEC webstore or a reseller.

Additions to the Declarable Substance List (DSL)

A couple of regulatory changes drove the addition of two new entries to the DSL – the EU REACH Candidate List and the Canadian “Products Containing Mercury Regulations (SOR/2014-254) “. The new entries are listed in the table below

DSL Changes Based on Regulatory Changes (MC-2015-01)

Specific SubstanceCAS numberTypical ApplicationsReportable ApplicationsReporting ThresholdBasis
1,2-benzenedicarboxylic acid, di-C6-10-alkyl esters; 1,2-benzenedicarboxylic acid, mixed decyl and hexyl and octyl diesters with ≥ 0.3% of dihexyl phthalate (EC No. 201-559-5)68515-51-5, 68648-93-1Plasticisers, lubricants, adhesives, coatings, cable compounding, polymer foils, PVC compound coatings, paints, thinners, paint removers, fillers, putties, plasters, ink and toners, greases, release products, polymer preparations and compounds, and semiconductorsAll0.1 mass%REACH Candidate List
Mercury/Mercury Compounds-Silver-oxide button cells, alkaline batteries, zinc carbon batteriesBatteries0.005 mass%Canadian Products Containing Mercury Regulations

EU REACH Candidate List

One of the two SVHCs added to the REACH Candidate List on June 15, 2015 was found to have potential uses within the EEE industry and was therefore included in the DSL. The validation team did not find any evidence that the other SVHC added to the Candidate List (which is used as a fragrance) is applicable to EEE.

Canadian Products Containing Mercury Regulations

The Products Containing Mercury Regulations specifies its mercury thresholds based on homogeneous materials. The 0.1 mass% of homogeneous materials for most products is harmonized with the mercury/mercury compounds threshold of EU RoHS. However, the 0.0005 mass% of homogeneous materials in batteries is stricter than the EU Battery Directive’s threshold of 0.0005 mass% of the entire battery.

The Canadian restriction is clearly stricter than the EU Battery Directive; however, there are other emerging battery regulations in Asia that are also stricter then the EU Directive but still based on the mass of the whole battery (0.0001 mass% of battery). This creates a dilemma in specifying the threshold that is the strictest. The Canadian regulation will typically be stricter in small batteries and the 0.0001 mass% of the battery may be stricter in larger batteries. Given the challenge in specifying which threshold is stricter, both thresholds are now specified as separate entries in the IEC 62474 DSL. Suppliers of a battery containing mercury or a product containing such a battery need to consider both thresholds when determining their declaration requirements. However, even if both thresholds are exceeded, the mercury/mercury compounds would be declared only once for each instance of mercury in the product. If both thresholds are exceeded, both thresholds should be listed in the declaration. In a future article, we’ll be providing information on how to do this in a material declaration.

Substance Groups with an Exhaustive List of Reference Substances.

For most declarable substance groups that are included in the DSL, the reference substance list (RSL) provides a list of example substances that are included in the substance group. These reference substance lists are indicative and no attempt has been made to provide an exhaustive set of such substances.

However, for a few declarable substance groups, the reference substance list is a complete (i.e. exhaustive) list of substances as specified in a regulation. For these substance groups with a complete substance list on the RSL, additional comments have been added to the DSL entries to clarify that the list is complete. The comment field now includes “Note: This declarable substance group has a complete list of substances that is specified in the reference substance list”. This should provide users with additional clarity.

The substance groups with a complete list of reference substances are provided in the table below.

Substance Groups with a complete list of reference substance

IDSubstance Group
00003Asbestos
00004Azocolourants and azodyes which form certain aromatic amines
00020Hexabromocyclododecane (HBCDD) and all major diastereoisomers identified: Alpha-hexabromocyclododecane Beta-hexabromocyclododecane Gamma-hexabromocyclododecane
00036Phthalates, Selected Group 1 (BBP, DBP, DEHP)
00037Phthalates, Selected Group 2 (DIDP, DINP, DNOP)
00103Perfluorooctanoic acid (PFOA) and individual salts and esters of PFOA
00104Perfluorooctanoic acid (PFOA) and individual salts and esters of PFOA

Changes to the Reference Substance List (RSL)

A few changes were made to the Reference Substance List (RSL).

  • The reference substances that are part of a complete list (as discussed above) had a comment added “This reference substance is part of a complete list as specified in the regulation or standard indicated in the BasisDescription field of the DSL entry”
  • The reference substance ” Trichlorotetrafluoropropane” (HCFC-224cc) included in the substance group “Ozone Depleting Substances (CFC, Halon, HBFC, HCFC & others)” had an incorrect CAS number listed. The CAS number was updated to 422-51-5.

 Material Classes

There were no changes to the Material Classes.

 Data Exchange Format (Developer’s Table and XML Schema)

The IEC 62474 Developer’s Table has been updated with one minor editorial change and no technical changes:

  • The definition of the “aboveThresholdLevel” attribute (ACB122) was revised to better explain how the field is used. The revised definition states: True/False response stating whether the substance is contained in the product above or below the stated threshold. If the substance is or may be at or above the stated Threshold, the response shall be “True”. If the substance is known to be below the stated Threshold, the response would be “False”.

There were no changes to the XML schema.

Entries that are new or revised will have a LastRevised date of 2015-07-15.

If anyone is aware of errors or omissions in the database (e.g. a regulated substances that is not included in the DSL but has potential EEE applications), please send an email to ECD Compliance and we will review and address with the  validation team.

For further information on IEC 62474 or for support on your substance management program, please contact ECD Compliance.

IEC 62474 database: http://std.iec.ch/iec62474

IEC 62474 database will be out of service starting July 11, 2015

The IEC 62474 database will undergoing an update starting this Saturday July 11, 2015 to implment changes for maintenance cycle MC-2015-01.  The following information will be updated:

  • declarable substances list,
  • reference substance list
  • developer’s table

There are no changes planned to the XML schema associated with this update cycle.

Updates to the IEC 62474 database are live updates; therefore the database will need to remain out of service until all changes have been made and verified. Extensive verification is performed during each maintenance cycle. The header message on the database will indicate when the system is out of service and when it is back in service.

Update to IEC 62474 Declarable Substance List is Released – April 8, 2015

The latest update to the IEC 62474 Declarable Substance List (DSL) and data exchange format was released on April 8, 2015. The DSL is revised to version D8.00 and the updated data exchange format (XML schema and developer’s table) are now version X6.00.

The DSL is an internationally recognized and harmonized list of substances and substance groups that are regulated and may be constituents of electrical and electronic products and systems. Major electrical and electronic manufacturers and suppliers use the DSL in their design and supply chain management operations to specify and control substances of concern. The list is typically updated twice a year.

Additions to the Declarable Substance List (DSL)

Regulatory changes drove five additions and modifications to the DSL, namely for the substance entries:

  • Benzenamine, N-phenyl-, reaction products with styrene and 2,4,4-trimethylpentene (BNST)
  • 2-ethylhexyl 10-ethyl-4,4-dioctyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate (DOTE)
  • reaction mass of 2-ethylhexyl 10-ethyl-4,4-dioctyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate and 2-ethylhexyl 10-ethyl-4-[[2-[(2-ethylhexyl)oxy]-2-oxoethyl]thio]-4-octyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate (reaction mass of DOTE and MOTE)
  • 2-(2H-benzotriazol-2-yl)-4,6-ditertpentylphenol (UV-328)
  • 2-benzotriazol-2-yl-4,6-di-tert-butylphenol (UV-320)

Four of the six SVHCs added to the REACH Candidate List in December 2014, have the potential to be final constituents of EEE above the reporting threshold and, therefore, passed the IEC 62474 screening process and were included. The UV-320 substance was already on the DSL based on another regulation, but its reporting threshold has now been updated to include the REACH SVHC threshold. For the other two SVHCs, no evidence was found that they occur in EEE and were therefore not added. If anyone is aware of these substances being used in EEE, please contact the IEC 62474 validation team by sending an email to iec62474(at)rohs.ca.

BNST is restricted in Canada under the Prohibition of Certain Toxic Substances Regulations, 2012 and has been used as an additive to lubricants to improve performance and reliability in several types of electric motors.  The regulations provided an exemption for BNST in lubricants until March 2015 and thereafter only by permit. As the global supply chain gains awareness of the restriction, applications of BNST lubricants have been turning up in a variety of applications from IT equipment, to HVAC equipment and starter motors and alternators.

The new and modified entries in the DSL due to new substance regulations are listed in Table 1 below.

Table 1: DSL Changes Due to New Regulations (MC-2014-02)

Specific SubstanceCAS numberTypical ApplicationsReportable ApplicationsReporting ThresholdBasis
Benzenamine, N-phenyl-, reaction products with styrene and 2,4,4-trimethylpentene68921-45-9Lubricant additive in motors and sliding mechanismsAllIntentionally addedCanadian Regulation
2-ethylhexyl 10-ethyl-4,4-dioctyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate (DOTE)15571-58-1PVC stabilizerAll0.1 mass%REACH Candidate List
reaction mass of 2-ethylhexyl 10-ethyl-4,4-dioctyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate and 2-ethylhexyl 10-ethyl-4-[[2-[(2-ethylhexyl)oxy]-2-oxoethyl]thio]-4-octyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate (reaction mass of DOTE and MOTE) PVC stabilizerAll0.1 mass%REACH Candidate List
2-(2H-benzotriazol-2-yl)-4,6-ditertpentylphenol (UV-328)25973-55-1UV stabilizerAll0.1 mass%REACH Candidate List
2-benzotriazol-2-yl-4,6-di-tert-butylphenol (UV-320)3846-71-7UV-stabilizer in adhesives, paints, printing inks, plastics, inked ribbons, putty, caulking or sealing fillersAllIntentionally added or 0.1 mass%REACH Candidate List

Cleanup of Declarable Substance List

In 2014, the IEC 62474 Validation Team (VT) launched a major review and cleanup of the substance names and substance group names in the current DSL and reference substance list (RSL). For example, in some cases, regulators have revised the spelling of a substance name, and in other cases alternate spellings may have been introduced by regulations in different countries. Nearly 30 current substance and substance group entries were identified and approved for revision.

As part of the DSL review, the VT also considered how to deal with substance names that are listed by regulators but are not chemically accurate or that include a description or synonym in the substance name.  For example, the European Chemical Agency (ECHA) is notorious for including a description of the substance in the substance name rather than providing a separate description field.   It’s important for the industry to have substance naming information that is meaningful to the upstream global supply base who may be several levels removed from importing products into the final destination country.

The Declarable Substance Group and Declarable Substance entries that were modified are listed in Table 2 at the end of this article.

For two of the substance entries (Dibutyltin dichloride (DBTC) and Cadmium sulphide), the substance group that was previously listed in the substance group was deleted.  Declarable Substance groups have not be consistently listed for declarable substances in the IEC 62474 DSL and given that regulations sometimes create overlapping substance groups, the VT has agreed to not prescribe a substance group for declarable substance entries. This provides users with more flexiblity in constructing the material declaration file and will reduce confusion when there there is more than one applicable substance group.

 Changes to the Reference Substance List (RSL)

The DSL cleanup also impacted a few of the entries in the Reference Substance List (RSL).

  • The substance group name for “Hexabromocyclododecane (HBCDD) and all major diastereoisomers” was expanded to “Hexabromocyclododecane (HBCDD) and all major diastereoisomers identified: Alpha-hexabromocyclododecane Beta-hexabromocyclododecane Gamma-hexabromocyclododecane” to align with the REACH Candidate List;
  • The declarable substance group name “Shortchain Chlorinated Paraffins (C10 – C13)” was renamed to “Alkanes, C10-13, chloro (Short Chain Chlorinated Paraffins)” to better align with he current naming convention that is used internationally;
  • The declarable substance group “Refractory Ceramic Fibres (RCF), Aluminosilicate” has been deleted (it is no longer referenced by the DSL);
  • The declarable substance group “Boric Acid” has been deleted (it is no longer referenced by the DSL);
  • Reference substances have been added for “Hexahydromethylphthalic anhydride”. The four reference substances provide a complete list of substances that are applicable to the substance group as specified in the regulation.

Material Classes

There were no changes to the Material Classes.

Data Exchange Format (Developer’s Table and XML Schema)

The IEC 62474 Developer’s Table has been updated with three minor changes

  • The reporting obligation for Mass and MassPercent elements in the MaterialClass Class were updated to allow only one of Mass or MassPercent to be provided for MaterialClass , but not both.  Similar changes were made to the Part, Material, SubstanceGroup, and Substance classes during the last update cycle. This change makes MaterialClass consistent with the other data elements;
  • The note associated with the reportableApplication (ACB123) was corrected. The note had previously suggested that reportable applications should be concatenated when multiple reportable applications are simultaneously triggered. For example, this can happen for declarable substance groups such as “lead/lead compounds” which have multiple entries in the DSL with different reportable applications and reporting thresholds. However, since the “Threshold” Class (ACA021) was created, multiple thresholds can now be reported by using multiple Threshold elements; concatenating reportable applications is no longer relevant (nor allowed) .
  • The definition of the MassPercent and Mass elements in “Material” (ACB048, ACB049) was modified to clarify that they refer to the mass of the material.

The XML Schema and developer’s table are now version X6.00. Changes in the X6.00 developer’s table compared to X5.00 version are shown in red font. There were no changes to the XML Schema in this update.  The X6.00 schema is identifical to the X5.00 schema.

Further Information

The declarable substance list (DSL) is available for download at http://std.iec.ch/iec62474. Entries that are new or revised may be identified by a LastRevised date of 2015-04-08 for the DSL and the developer’s table.

For further information on IEC 62474 or for support on your substance management program, please contact ECD Compliance.

Annex I – Declarable Substance Group and Declarable Substance Entries that were modified as part of the DSL Cleanup

Table 2: Updated Substance Entries Based on Review of DSL (MC-2014-02)

IDSubstance Group or SubstanceCAS numberReportable ApplicationsReporting Threshold
00013Cobalt dichloride7646-79-9All0.1 mass%
00020Hexabromocyclododecane (HBCDD) and all major diastereoisomers identified: Alpha-hexabromocyclododecane Beta-hexabromocyclododecane Gamma-hexabromocyclododecaneSee Reference Substance worksheet for more detailsAllIntentionally added or 0.1 mass%
00026Lead chromate7758-97-6All0.1 mass%
00027Lead chromate molybdate sulphate red (C.I. Pigment Red 104)12656-85-8All0.1 mass%
00028Lead sulfochromate yellow (C.I. Pigment Yellow 34)1344-37-2All0.1 mass%
00038Bis (2-ethylhexyl)phthalate (DEHP)117-81-7All0.1 mass%
00039Dibutyl phthalate (DBP)84-74-2All0.1 mass%
00040Benzyl butyl phthalate (BBP)85-68-7All0.1 mass%
00041Diisobutyl phthalate84-69-5All0.1 mass%
000421,2-Benzenedicarboxylic acid, di-C6-8-branched alkyl esters, C7-rich71888-89-6All0.1 mass%
000431,2-Benzenedicarboxylic acid, di-C7-11-branched and linear alkyl esters68515-42-4All0.1 mass%
00052Alkanes, C10-13, chloro (Short Chain Chlorinated Paraffins)See Reference Substance worksheet for more detailsAllIntentionally added or 0.1 mass%
00054Bis(tributyltin) oxide (TBTO)56-35-9AllIntentionally added or 0.1 mass%
00056Tris(2-chloroethyl)phosphate115-96-8All0.1 mass%
000574-(1,1,3,3-tetramethylbutyl)phenol140-66-9All0.1 mass%
00061Potassium hydroxyoctaoxodizincatedichromate11103-86-9All0.1 mass%
00064Bis(pentabromophenyl) ether (decabromodiphenyl ether) (DecaBDE)1163-19-5All0.1 mass%
00070Tetralead trioxide sulphate12202-17-4All0.1 mass%
00081Diisopentylphthalate605-50-5All0.1 mass%
00096Pentadecafluorooctanoic acid (PFOA)335-67-1All0.1 mass%
00050Aluminosilicate Refractory Ceramic FibresAll0.1 mass %
00051Zirconia Aluminosilicate Refractory Ceramic FibresAll0.1 mass %
00076Dibutyltin dichloride (DBTC)683-18-1All0.1 mass%
00099Cadmium sulphide1306-23-6All0.1 mass%
00077Lead cyanamidate20837-86-9All0.1 mass%
00092Hexahydromethylphthalic anhydrideSee Reference Substance worksheet for more detailsAll0.1 mass%
00007Boric Acid10043-35-3, 11113-50-1All0.1 mass%
00090Di-isodecyl phthalate (DIDP)68515-49-1, 26761-40-0AllIntentionally added
00091Di-n-hexyl Phthalate (DnHP)84-75-3AllIntentionally added or 0.1 mass%
00079Silicic acid (H2Si2O5), barium salt (1:1), lead-doped68784-75-8All0.1 mass%

IEC 62474 Database will be Out of Service Starting April 4, 2015 for a Substances and Data Exchange Update

The IEC 62474 database which the EEE industry declarable substance list and data exchange format will be undergoing a content update starting on Saturday, April 4, 2015.  This is a live update therefore the information on the database will be in transition from April 4th until the update is complete and has been verified. A new header message will be posted on the IEC 62474 DB website once the update is complete.

Any data that is viewed or downloaded starting on April 4th should be considered invalid and not used for material declaration purposes.

The forecast completion date for the database update is Thursday, April 9. Confirmation will be provided on the database.

Updates to IEC 62474 Declarable Substance List and Data Exchange – September 24, 2014

An update to the IEC 62474 Declarable Substance List (DSL) and data exchange format was released on September 24, 2014. Voting on proposed changes closed on September 12, 2014 — all changes were approved. The DSL has been up-revisioned to version D7.00 and the updated XML schema and associated developer’s table are now version X5.00.

The DSL is an internationally recognized and harmonized list of substances and substance groups that are regulated and may be a constituent of electrotechnical products. Major electrical and electronic manufacturers and suppliers use the DSL in their design and supply chain management operations to specify and control substances of concerns. The list is typically updated twice a year.

Additions to the Declarable Substance List (DSL)

The most recent additions to the DSL are:

  • Disodium 4-amino-3-[[4′-[(2,4-diaminophenyl)azo][1,1′-biphenyl]-4-yl]azo]
    -5-hydroxy-6-(phenylazo)naphthalene-2,7-disulphonate (C.I. Direct Black 38) (EU REACH SVHC)
  • Diisohexyl phthalate (DiHP) (EU REACH SVHC)
  • Diisononyl phthalate (DINP) (California Prop 65)
  • The eight polycyclic aromatic hydrocarbon (PAH) (EU REACH ANNEX XVII)

Direct Black 38 is a REACH SVHC that was added to the Candidate list in December 2013; however, it’s addition to the IEC 62474 DSL required further assessment and therefore was not added during the previous update in April 2014.

Of the four SVHCs added to the REACH Candidate List in June 2014, DiHP is the only SVHC that passed the IEC 62474 screening process as a possible constituent in EEE products above the reporting threshold. The other three SVHCs are intermediate substances which did not pass the screening process.

For the polycyclic aromatic hydrocarbon (PAH) substances, it’s important to note that each PAH substance appears in two separate entries with two different reportable applications and reporting thresholds.

Modifications to existing entries

  • Brominated flame retardants (other than PBBs, PBDEs, or HBCDD) – the reporting threshold was updated to more clearly indicate that the mass percent needs to be calculated at the material level (0.1 mass% of bromine in plastic materials)
  • Chlorinated Flame Retardants (CFR) – the reporting threshold was updated to more clearly indicate that the mass percent needs to be calculated at the material level “0.1 mass% chlorine in plastic materials”
  • Shortchain Chlorinated Paraffins (C10 – C13) – the reporting threshold was updated to “Intentionally added or 0.1 mass%” based on the EU POP regulation
  • Perfluorooctane sulfonates (PFOS) – the existing entry is being replaced by two separate entries to reflect the different reporting thresholds for “Textiles or other coated materials” versus other applications
  • Hexabromocyclododecane (HBCDD) and all major diastereoisomers – the reporting threshold is being updated to include “intentionally added”.

The new and modified entries in the DSL are shown in the table at the end of this post. The reference substances and the material class did not change during this update.

Changes to the XML Schema

A new class definition (“Threshold”) was created to pull together the reportableApplication, reportingThreshold, and aboveThreshold attributes.  The re-organization of the attributes offers signfiicant advantage in interpreting material declarations when more than one reporting requirement (i.e. DSL entry) is triggered. This issue is likely to become more common as reporting requirements become more complex and more DSL entries overlap.

The reportable application, reporting threshold and above threshold data fields were previously specified as indepedent attributes within the substance and substance group classes.  They are now grouped together into the “Threshold” class and clearly associated with each other to form a grouping of information that corresponds to a single reporting requirement.

In this way, multiple reporting triggers can be easily recorded for a substance or substance group.  This can occur, for example, when a given substance or substance group that has multiple DSL entry (such as Lead/lead compounds or some of the Phthalate substances) needs to be declared because multiple entries have been triggered. The multiple entries may exist in the DSL because of different applications and/or reporting thresholds. Although multiple DSL entries have been triggered, if there is only one instance of the substance then it would be reported only once in the material declaration file and all of the reporting triggers should be recorded with the substance.

As a consequence of adding the new “Threshold” class, attributes ACB067, ACB068, ACB117, ACB068, ACB069, and ACB118 are no longer required and have been deleted.

Changes to the Developer’s Table

The IEC 62474 Developer’s Table has been updated with three changes

  • added “Threshold” class to replace individual attributes for reportableApplication, reportingThreshold, and aboveThreshold (see description above);
  • modification to the wording and reporting obligation for mass, mass percent, material mass percent reporting obligations;
  • clarification of reporting requirement for mass or masspercent information in product parts.

The working group that originally developed IEC 62474 clarified that the a user creating a material declaration should only provide either mass or mass percent information, but not both. Inconsistency between reported mass and mass percent values can create confusion as to which value is actually correct.  In some cases, differences may be inadvertently introduced due to rounding.  Therefore, the validation team has updated the obligation fields for mass and mass percent to modify the wording  to require either mass or masspercent but not both (to avoid potential inconsistency). The exact wording will vary between mass information for ProductID, MaterialClass, Material, SubstanceGroup and Substance.

The ACB032 and ACB033 entries in the developer’s tables now include comments to clarify that “When ‘ProductID Class’ refers to ‘ProductPart Class’, the Mass (MassPercent) corresponds to one unit of the product part.

The updated XML Schema and developer’s table are version X5.00.  Changes in the developer’s table compared to X4.00 are shown in red font.

Further Information

The declarable substance list (DSL) is available for download at http://std.iec.ch/iec62474. Entries that are new or revised may be identified by a LastRevised date of 2014-09-24 for the DSL and 2014-09-24 for the developer’s table.

For further information on IEC 62474 or for support on your substance management program, please contact ECD Compliance.

New and Modified DSL Entries (MC-2014-01)

Substance GroupSpecific SubstanceCAS numberTypical ApplicationsReportable ApplicationsReporting Treshold
Disodium 4-amino-3-[[4'-[(2,4-diaminophenyl)azo][1,1'-biphenyl]-4-yl]azo] -5-hydroxy-6-(phenylazo)naphthalene-2,7-disulphonate (C.I. Direct Black 38)1937-37-7used in ink for printersAll0.1 mass%
1,2-Benzenedicarboxylic acid, dihexyl ester, branched and linear68515-50-4 Used as a plasticizer for certain plastics and rubbersAll0.1 mass%
Diisononyl phthalate (DINP)28553-12-0, 68515-48-0Used as a plasticizer for PVCAllIntentionally added
Benzo[a]pyrene50-32-8Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts that come into direct, prolonged or repetitive skin or oral cavity contact except those for toys or childcare articles0.0001 mass% of the plastic or rubber part
Benzo[e]pyrene192-97-2Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts that come into direct, prolonged or repetitive skin or oral cavity contact except those for toys or childcare articles0.0001 mass% of the plastic or rubber part
Benzo[a]anthracene56-55-3Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts that come into direct, prolonged or repetitive skin or oral cavity contact except those for toys or childcare articles0.0001 mass% of the plastic or rubber part
Chrysen218-01-9Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts that come into direct, prolonged or repetitive skin or oral cavity contact except those for toys or childcare articles0.0001 mass% of the plastic or rubber part
Benzo[b]fluoranthene205-99-2Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts that come into direct, prolonged or repetitive skin or oral cavity contact except those for toys or childcare articles0.0001 mass% of the plastic or rubber part
Benzo[j]fluoranthene205-82-3Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts that come into direct, prolonged or repetitive skin or oral cavity contact except those for toys or childcare articles0.0001 mass% of the plastic or rubber part
Benzo[k]fluoranthene207-08-9Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts that come into direct, prolonged or repetitive skin or oral cavity contact except those for toys or childcare articles0.0001 mass% of the plastic or rubber part
Dibenzo[a,h]anthracene53-70-3Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts that come into direct, prolonged or repetitive skin or oral cavity contact except those for toys or childcare articles0.0001 mass% of the plastic or rubber part
Benzo[a]pyrene50-32-8Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts of toys and childcare articles that come into direct, prolonged or repetitive skin or oral cavity contact0.00005 mass% of the plastic or rubber part
Benzo[e]pyrene192-97-2Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts of toys and childcare articles that come into direct, prolonged or repetitive skin or oral cavity contact0.00005 mass% of the plastic or rubber part
Benzo[a]anthracene56-55-3Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts of toys and childcare articles that come into direct, prolonged or repetitive skin or oral cavity contact0.00005 mass% of the plastic or rubber part
Chrysen218-01-9Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts of toys and childcare articles that come into direct, prolonged or repetitive skin or oral cavity contact0.00005 mass% of the plastic or rubber part
Benzo[b]fluoranthene205-99-2Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts of toys and childcare articles that come into direct, prolonged or repetitive skin or oral cavity contact0.00005 mass% of the plastic or rubber part
Benzo[j]fluoranthene205-82-3Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts of toys and childcare articles that come into direct, prolonged or repetitive skin or oral cavity contact0.00005 mass% of the plastic or rubber part
Benzo[k]fluoranthene207-08-9Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts of toys and childcare articles that come into direct, prolonged or repetitive skin or oral cavity contact0.00005 mass% of the plastic or rubber part
Dibenzo[a,h]anthracene53-70-3Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts of toys and childcare articles that come into direct, prolonged or repetitive skin or oral cavity contact0.00005 mass% of the plastic or rubber part
Brominated flame retardants (other than PBBs, PBDEs, or HBCDD)See Reference Substance worksheet for more detailsSee Reference Substance worksheet for more detailsFlame retardant for housing, connectors, package molding sealingPlastic materials except printed wiring board laminates0.1 mass% of bromine in plastic materials
Chlorinated Flame Retardants (CFR)See Reference Substance worksheet for more detailsSee Reference Substance worksheet for more detailsflame retardant for housing, connectors, package molding sealingPlastic materials except printed wiring board laminates0.1 mass% chlorine in plastic materials
Shortchain Chlorinated Paraffins (C10 – C13)See Reference Substance worksheet for more detailsSee Reference Substance worksheet for more detailsPlasticizer for PVC, flame retardantAllIntentionally added or 0.1 mass%
Perfluorooctane sulfonates (PFOS)See Reference Substance worksheet for more detailsSee Reference Substance worksheet for more detailsAntistatic agent for films and plasticsTextiles or other coated materials.
Intentionally added or 1 microgram/m2 of coated material
Perfluorooctane sulfonates (PFOS)See Reference Substance worksheet for more detailsSee Reference Substance worksheet for more detailsAntistatic agent for films and plasticsAll except textiles or other coated materials.
Intentionally added or 0.1 mass% of the part (as the sum of PFOS)
Hexabromocyclododecane (HBCDD) and all major diastereoisomersSee Reference Substance worksheet for more detailsSee Reference Substance worksheet for more detailsFlame retardant; mainly used for expanded polystyrene and some types of fiberAllIntentionally added or 0.1 mass%

Substances that are a Trade Secret

Material declarations are a sensitive topic for material and part manufacturers that are using certain chemicals that they consider a trade secret. The chemical, its application, and/or the exact composition usually provides a competitive advantage that the manfuacturer wishes to protect.

The IEC 62474 material declaration standard allows manufacturers flexibility on how much of the chemical composition of the product they wish to declare. A manufacturer could provide a full material declaration of all substances except for those that are trade secrets.

However, if the “trade secret” includes a substance or substance group that is listed on the IEC 62474 declarable substances list (DSL) with a mandaotry reporting requirement and it is present above the reporting threshold, then there is no flexibility; it must be included in the material declaration. The mandatory reporting requirement indicates that the substance is regulated and if it is used in a confidential manner, it can still cause a product to become non-compliant to a legal obligation. Therefore, it is not allowed to leave out or try to hide such a substance in the material declaration.