BNST Restriction in Lubricants in EEE Approaching in March 2015

BNST (Benzenamine, N-phenyl-, Reaction Products with Styrene and 2,4,4-Trimethylpentene) has been used in lubricants in motors and other sliding mechanisms in many types of electrical and electronic products.  The substance is added to lubricants as an additive that provides performance enhancements as an antioxidant, corrosion inhibitor, tarnish inhibitor, and scavenger and antiscaling agent. BNST containing lubricants may be found in some computer storage drives and other applications with a motor.

BNST was restricted in Canada under the Prohibition of Certain Toxic Substances Regulations, 2012 beginning on March 14, 2013; however, a 2 year exemption for use of BNST as an additive in lubricants has extended the use period for applications in the EEE industry.

Although the general exemption in lubricants expires on March 13, 2015, manufacturers and importers may apply for a permit to continue manufacturing and importing products and parts (such as motors) that contain BNST in the lubricant after March 2015. Even if BNST is being designed out of new products, there is still a significant challenge for OEMs that need to continue providing spare parts for the repair of existing products — there is no exemption in the regulation for spare parts. Environment Canada requires 60 working days to process a permit application; therefore they are requesting that all applications should be submitted by no later than December 1, 2014 in order to have the permit issued on time.

The permit application includes requirements for information on BNST use and plans for phasing out the substance from your products.  Environment Canada has stated that applications not meeting specific minimum requirements cannot be approved.

The Prohibition Regulation is available for download from the Canada Gazette.

For support on completing and submitting a permit application, contact ECD Compliance.