Tag Archives: Material Declaration

IEC 62474 Declarable Substance List (DSL) – July 2018 Update

The IEC 62474 Declarable Substance List (DSL) was updated to Version D16.00 on July 8, 2018. The update includes relevant SVHCs from the recent update to the EU REACH Candidate List and a few other changes to declarable substance and reference substance entries as described below.

Declarable Substance List (DSL)
Eight of the ten SVHCs added to the REACH Candidate List on June 27th were included in the DSL based on their potential presence in EEE products. The substance review for possible EEE uses was conducted by the IEC 62474 Validation Team (VT62474) with experts from Asia, Americas, and Europe. Note: if anyone is aware of information that may be relevant to whether or not one of the substances may be present in EEE products, please forward the information to the VT (by sending an email to iec62474(at)rohs.ca).

One of the additions, the phthalate DCHP, had been proposed for the Candidate List in 2016, but the Member State Committee (MSC) representing the EU countries couldn’t agree as to whether or not it met the requirements for listing. The substance was referred to the European Commission who made the final decision and issued Commission Implementing Decision (EU) 2018/636 in April to add the substance.

The additions to the DSL are listed in Table below.

One entry was deleted from the DSL. The restriction of BNST (Benzenamine, N-phenyl-, reaction products with styrene and 2,4,4-trimethylpentene) was repealed by Canada and the DSL entry (ID=00127) was accordingly deleted from the DSL.

IDSpecific SubstanceCAS numberCommon SynonymsTypical ApplicationsReportable ApplicationsReporting Threshold
00148Benzo[ghi]perylene191-24-2Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersAll0.1 mass% of article
00149Octamethylcyclotetrasiloxane556-67-2D4Siloxanes are monomers used to manufacture silicones. They may remain as unreacted in silicone polymers and copolymers, used in many electrotechnical equipment product categories.All0.1 mass% of article
00150Decamethylcyclopentasiloxane541-02-6D5Siloxanes are monomers used to manufacture silicones. Residuals may remain in silicone polymers and copolymers.All0.1 mass% of article
00151Dodecamethylcyclohexasiloxane540-97-6D6Siloxanes are monomers used to manufacture silicones. They may remain as unreacted in silicone polymers and copolymers, used in many electrotechnical equipment product categories.All0.1 mass% of article
00152Disodium octaborate12008-41-2Wooden veneer sheets and pressed wooden panels (as a constituent within the starch adhesive), as a flame retardant, as stabilizer in aminoplastic resins, and as a biocide in professional and industrial wood preservation.All0.1 mass% of article
00153Terphenyl, hydrogenated61788-32-7 Plasticizers, sealants, epoxy adhesives, paints and heat sinksAll0.1 mass% of article
00154Lead7439-92-1Steel, aluminum and copper alloys, lead acid batteries, solder and other applicationsAll0.1 mass% of article
00139Dicyclohexyl phthalate84-61-7DCHPPlasticizer, dye, pigment, paint, ink, manufacture of adhesive, lubricantAll0.1 mass% of article

Reference Substance List (RSL)
Nine reference substances were deleted from the Reference Substance List (RSL). The substances are SVHCs that are on the REACH Candidate List; however, they have been previously screened out because no applications were found whereby the substances would remain in EEE products at or above the reporting threshold level. To avoid confusion that can arise when a regulated substance is on the RSL but not on the DSL, the VT 62474 agreed to remove the substances from the RSL for consistency.

One other RSL entry was modified. The RSL entry R00147 (substance name “Hexabromocyclododecane (HBCDD)”) was modified to remove the CAS registry number “3194-55-6”. In January 2018, a new entry (R00492) was added to the RSL with the specific substance represented by this CAS number  (1,2,5,6,9,10-hexabromocyclodecane), so listing the CAS number against the generic substance entry was no longer needed. To avoid confusion from having the same CAS number listed in two different RSL entries for the same substance group, the CAS number was removed from the generic entry.

Additions and modifications to the Reference Substance List (RSL) are shown in the Table below.

Type of ChangeIDSubstance GroupSpecific SubstanceCAS number
DeletedR00099Cadmium/Cadmium compoundsCadmium chloride10108-64-2
DeletedR00100Cadmium/Cadmium compoundsCadmium sulfate10124-36-4, 31119-53-6
DeletedR00103Chromium (VI) CompoundsChromium trioxide1333-82-0
DeletedR00104Chromium (VI) CompoundsSodium chromate7775-11-3
DeletedR00105Chromium (VI) CompoundsSodium dichromate10588-01-9, 7789-12-0
DeletedR00107Chromium (VI) CompoundsPotassium dichromate7778-50-9
DeletedR00108Chromium (VI) CompoundsPotassium chromate7789-00-6
DeletedR00162Lead/Lead CompoundsLead (II) oxide1317-36-8
DeletedR00204Ozone Depleting Substances (CFC, Halon, HBFC, HCFC & others)1-Bromopropane106-94-5
ModificationR00147Hexabromocyclododecane (HBCDD)Hexabromocyclododecane (HBCDD)25637-99-4

Material Class List (MCL)
No changes were made to the MCL during this update to the IEC 62474 database. However, a major revision to the Material Class List is currently underway — the changes will better support Life Cycle Assessment (LCA) of EEE products.

Upcoming Major Changes to the IEC 62474 Standard and Database
The IEC 62474 standard was due for its periodic review and revision a couple years ago (like any other IEC standard) and the IEC/TC111 Maintenance Team has been working hard to improve the standard based on feedback we’ve received from many users and other stakeholders.

The FDIS version (Final Draft International Standard) of the revised standard was completed in March and is currently in translation; it should be available for voting at the end of July (voting is by country). In the interim, the VT62474 is busy drafting the changes to the XML schema to meet the new requirements and compiling other information that will be added to the database such as new data fields for the DSL and exemption lists. We will be posting additional information on this site over the next few months.

For immediate guidance, ECD Compliance supports manufacturers, solution providers, and suppliers on the implementation of IEC 62474. We can work with you on the transition to the new requirements and provide implementation guidance. For additional information, contact ECD Compliance.

The IEC 62474 Database
The IEC 62474 DSL is available on the IEC 62474 database at: http://std.iec.ch/iec62474. The new and modified entries have a last revised date of 2018-07-08.

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 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

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.