EU – RoHS Phthalate Restrictions take Effect Starting July 22, 2019

EEE Manufacturers are reminded that the phthalate restrictions for DEHP, DBP, BBP, and DIBP are in effect for any EEE products in RoHS categories 1-7, 10, and 11 that are placed on the market starting July 22, 2019.

Name of SubstanceCas No.
Bis(2-ethylhexyl) phthalate (DEHP)117-81-7
Dibutyl phthalate (DBP)84-74-2
Benzyl butyl phthalate (BBP)85-68-7
Diisobutyl phthalate (DIBP)84-69-5

The new EU RoHS requirements are applicable based on when individual product units are “placed on the market”.

Impact on EEE Manufacturers

Organizations that meet the definition of ‘Manufacturer’ under the EU RoHS Directive and have products that are in scope of the new phthalate restrictions should confirm that they are meeting all obligations listed under the EU ROHS Directive Article 7 (Obligations of manufacturers).  This includes updating the technical documentation to demonstrate that the four phthalate substances are not in the product above the 0.1 mass% of homogeneous material threshold.

Repair and return systems may also need to be updated to ensure that any RMA units shipped to customers in the EU either (1) meet the new substance restrictions, or (2) were previously been placed on the EU market before the new restrictions came into effect.

ECD Compliance can provide assistance with compliance to the new phthalate restrictions.