EU – Proposed Restriction of Microplastics, Formaldehyde and D4, D5 and D6

ECHA has submitted proposals to restrict:

  • microplastics (EC -, CAS -);
  • formaldehyde and formaldehyde releasers (EC -, CAS -); and
  • octamethylcyclotetrasiloxane (D4) (EC 209-136-7, CAS 556-67-2), decamethylcyclopentasiloxane (D5) (EC 208-764-9, CAS 541-02-6) and dodecamethylcyclohexasiloxane (D6) (EC 208-762-8, CAS 540-97-6).

The proposed siloxane restriction (D4, D5, and D6) has raised concerns from European industry groups.  D4, D5, and D6 are used in the production of silicone polymer sealants and may therefore be present as impurities.  They argue that the restriction will have “unintended consequences” for the environment given that “the use of silicone polymers reduces the carbon footprint of countless other sectors.”  They describe the use of the siloxanes as an important area for innovation of silicone polymers.

ECHA is accepting comments on the proposal until 20 September 2019.

 Impact on EEE Manufacturers

Given that silicone polymers are commonly used in the manufacturing of EEE, the potential presence of D4, D5, and D6 should be reviewed by EEE manufacturers.

Note: Some manufacturers may use silicone polymers as a shop floor material and therefore it may not necessarily show up on the product’s bill of materials.