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%