RoHS – International RoHS Standardization Forum

The International RoHS Standardization Forum took place on October 26, 2018 in Busan, Korea.  The topics presented at the forum were split between substance regulations and International Standards that support compliance to substance regulations. We provide a brief summary of the presentations.  For copies of the presentations, please contact your ECD Compliance prime.

IEC TC111 WG3 Past, Present and Future

This presentation focused on the analytical test methods that are available or under development for RoHS and REACH substance testing. The test methods are included in the IEC 62321-X series of test methods.  Some of the test methods are screening methods that are intended to be quick and inexpensive, usually covering several elements or substances with one test and often without damaging the product. Other methods utilize analytical chemistry whereby the sample is digested into a solution and then analyzed using methods such as gas chromatography (GC), mass spectrometry (MS), combustion-ion chromatography, inductively coupled plasma (ICP), colorimetric method, atomic absorption spectroscopy (AAS), etc. A list of current and under development test methods are provide in Table 6.

Table 6: IEC 62321-X Standards

PartIEC 62321 Determination of certain substances in electrotechnical products –Edition 1.0Status
1Part 1: Introduction and overview (2013-05-17)Published
2Part 2: Disassembly, disjunction and mechanical sample preparation (2013-06-25)Published
Part 3-1: Screening -Lead, mercury, cadmium, total chromium and total bromine using X-ray fluorescence spectrometry (2013-06-19)Published
Part 3-2: Screening -Total bromine in polymers and electronics by Combustion -Ion Chromatography (2013-06-19)Published
Part 3-2 Screening of fluorine, bromine, chlorine and iodine in polymer and electronics by Combustion -Ion Chromatography (C-IC).Revision under Development
Part 3-3 Screening of polybrominatedbiphenyls, polybrominateddiphenylethers and phthalates in polymers by pyrolysis (Py-GC-MS) or thermal desorption (TD-GC-MS) gas chromatography-mass spectrometry.Under Development
4Part 4: Mercury in polymers, metals and electronics by CV-AAS, CV-AFS, ICP-OES and ICP-MS (2013-06-19)Published
5Part 5: Cadmium, lead and chromium in polymers and electronics and cadmium and lead in metals by AAS, AFS, ICP-OES and ICP-MS (2013-06-25Published
6Part 6: Polybrominatedbiphenyls and polybrominateddiphenylethers in polymers by gas chromatography–mass spectrometry (GC-MS) (2015-06)Published
7-1Part 7-1: Presence of hexavalent chromium (Cr(VI)) in colourlessand colouredcorrosion-protected coatings on metals by the colorimetric method” (2015-09)Published
Part 7-2: Determination of hexavalent chromium (Cr(VI)) in polymers and electronics by the colorimetric method (2017-03)Published
8Part 8: Phthalates in polymers by gas chromatography-mass spectrometry (GC-MS), gas chromatography-mass spectrometry using a pyrolyzer/thermal desorption accessory (Py-TD-GC-MS)Published
9Hexabromocyclododecanein polymers by high pressure liquid chromatography-mass spectrometry (LC-MS)Under Development
10Polycyclic aromatic hydrocarbons (PAHs) in polymers and electronics by gas chromatography-mass spectrometry (GC-MS)Under Development
11Tris(2-chloroethyl) phosphate (TCEP) in polymers and electronics by gas chromatography-mass spectrometry (GC-MS) and liquid chromatography-mass spectrometry (LC-MS)Under Development

Each new test method goes through an International Intra-laboratory study to assess the reliability and repeatability of the test method.  Each of several labs from around the world are given samples to test according to the draft test method without knowing the content of the samples.  The results are compiled, and the accuracy and the reliability of the test method is assessed.  If the results are not sufficiently accurate and consistent, the test method goes back to the drawing board.

US CPSC Organo-Halogen FR Guidance Regarding Petition 2015 HP 15-1

An overview was provided of US Consumer Product Safety Commission (CPSC) ruling to ban Organo-Halogen flame retardants and the subsequent guidance to manufacturers, importers, distributors, retailers, and consumers.  The ban is intended to address exposure from additive, non-polymeric organohalogen FRs (OFRs) found in several products, including plastic casings surrounding electronics.

The rulemaking for the ban is currently under development (although unlikely to be enacted by the current US administration) and, in the interim, a guidance document was published in the US federal register Vol. 82 / No. 187 on Thursday September 28, 2017. The US National Academy of Sciences is currently investigating the feasibility of a ban and is expected to deliver their finding in Spring 2019.

The presentation also discusses four subnational regulations banning halogenated flame retardants in San Francisco, Maine, and Rhode Island, and Massachusetts, although none of those directly target electronics products.

Regulatory and standardization update on chemical substances in Europe

This presentation covered emerging changes to EU RoHS, challenges in REACH compliance, substance regulations and the circular economy, and critical raw materials (CRM) in the EU.

Topics for EU RoHS were the upcoming phthalate restrictions, exemption renewals, and seven additional substances under assessment – all of which have been previously covered in the ECD monthly reports. A brief summary of the European Commission’s recently launched roadmap for the RoHS Directive (RoHS 3).  A review of the Directive and a proposal for a recast (if appropriate) must be completed by July 2021.  The review includes: scope of the Directive, interface with other chemical, product and waste legislation, and is intended to consider effectiveness, efficiency, relevance, coherence with other legislation, and EU added value.

During the update on the EU REACH regulation, the hot topics included the “once an article, always an article” SVHC reporting requirements and the upcoming ECHA database on SVHCs in articles. There are still many aspects of SVHCs in the first article that are not practical to implement; the Commission and member states have acknowledged that “some level of aggregation needed, for practical reason”, but so far there has been no interest from member states to establish an expert group to deal with this issue.  The presentation indicated that several industry associations have developed detailed sectoral guidelines (ACEA, COCIR, ASD), but ECHA has made it clear that they will not endorse sectoral guidance.  The issue remains unresolved. An enforcement project b2b SVHC communication is currently wrapping up with a report expected by mid-2019.

An upcoming EU standard on declaration of critical raw materials is expected to be published in March 2019.

Recent Japanese Activity regarding Chemicals in Products & Phthalate analysis

This presentation provided an overview of the Japanese government sponsored chemSHERPA material declaration system. chemSHERPA supports two information formats; one for article information (AI) and one for chemical information (CI) for raw chemicals and mixtures.  chemSHERPA is based on the IEC 62474 material declaration format.

Other topics included screening and testing methods for phthalates, especially the necessity for fast and inexpensive screening methods given the high occurrence of phthalates use in the supply chain. An International Interlaboratory study on phthalates was conducted in 2018 with some optimistic results: FT-IR was only effective for high concentration levels (above 5%).  HPLC/UV screening successfully separated seven different phthalates, but screening time took up to 20 minutes. As a result of the business need for phthalate screening and the results of the IIS, a new work item proposal is planned for an IEC 62321-X standard for phthalate screening.

The updated development of China RoHS and its standardization

Director of the China Electronics Standardization Institute (CESI) presented an overview and update on the China RoHS 2.0 regulation.  The first batch of products included in the RoHS product catalogue, the restricted substances and the list of exemptions were published earlier in 2018; however, the exact requirements for demonstrating conformity assessment have been an unnerving, open question for manufacturers.

The presentation suggested that two ways to demonstrate conformity will be provided: (1) self declaration, or (2) voluntary certification for China RoHS or State Green product certification. The self declaration approach is welcome news for manufacturers, but there are still a few details unanswered.  For example, the current expectation is that manufacturers (or importers) will need to upload their declarations into a central repository – however, the details, including any supporting information that needs to be provided has not been specified.