Author Archives: ECD_admin

Argentina – Proposed WEEE Bill Includes RoHS Restrictions

Argentina proposed a waste electronics (WEEE) bill in November 2014 that includes RoHS substance restrictions that would come into effect 2 years after the regulation enters into force. The bill, 9042-D-2014 titled “Management of Waste Electrical and Electronic Equipment”, would cover all 10 categories of EEE products as specified in the EU WEEE Directive and also batteries.

The proposed substance restrictions include the same six substances controlled by the EU’s RoHS Directive – lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE). Products containing these substances would be banned from sale in the Argentine market.

California – OEHHA Proposes New Proposition 65 Warning Labels

The California Office of Environmental Health Hazard Assessment (OEHHA) has issued a notice proposing changes to California Proposition 65 with the warning labels and other information provided to consumers. The new regulatory text, which is titled “Clear and Reasonable Warning”, is available on the OEHHA website. A public hearing on the proposed changes will be held on March 25, 2015.

Proposition 65 requires manufacturers and importers to provide a warning to purchasers when a user can potentially be exposed to any of the listed substances. Although over 900 substances are included in Proposition 65, only about a dozen of them (including lead, cadmium, and hexavalent chromium) are frequently litigated. When such a substance is present, organizations have typically labelled the product with the vague statement “This product contains chemicals known to the State of California to cause cancer and birth defects or other reproductive harm”. Under the revised regulation, more specific information about the substance and the risk it poses to the user must be provided.

EnergyStar – Update on Large Network Equipment (LNE) Test Method

For the emerging large network equipment (LNE) Energy Star specification , the U.S. EPA and DOE are requesting stakeholders to provide comments and proposals on two test method issues that were discussed at the January 30th, 2015 meeting: the use of the snaked traffic topology, and the ambient temperature requirement. Additional information on the issues and the request for proposals is provided in the request letter posted on the Energy Star LNE website.

The U.S. EPA will also be hosting a series of working group sessions to discuss outstanding issues related to developing an LNE specification.

On January 30th, 2015, the U.S. Environment Protection agency (EPA) and the U.S. Department of Energy (DOE) hosted a meeting to discuss the ENERGY STAR® Large Network Equipment (LNE) program. In acknowledgement of the complexity of LNE products, during that call, EPA proposed hosting a series of phone – based working sessions over the coming months to discuss key outstanding issues. With this letter, EPA is outlining the topics and timing for those conference calls. EPA welcomes stakeholder feedback on additional topics for discussing during the working calls.

 

California – 14 substances added to California Proposition 65

The California Office of Environmental Health Hazard Assessment (OEHHA) added 14 substances to the California Prop 65 list of chemicals known to the State to cause cancer. The newly added substances include:

  • the substance group dibenzanthracenes and the individual substances making up the group that were not already listed.
  • N- nitrosomethyl-n-alkylamines with alkyl chain lengths of 3 to 12 and 14carbons (The N-nitrosomethyl-n-alkylamines with 1 and 2 carbons were already listed in prop 65.)

Table 4: Fourteen (14) Substances Added to California Proposition 65

ChemicalCAS No.Toxicological Endpoints
Dibenzanthracenes---cancer
Dibenz[ a,c ]anthracene215-58-7cancer
Dibenz[ a,j ]anthracene224-41-9cancer
N-Nitrosomethyl- n -propylaminecancer
N-Nitrosomethyl- n -butylaminecancer
N-Nitrosomethyl- n -pentylaminecancer
N-Nitrosomethyl- n -hexylaminecancer
N-Nitrosomethyl- n -heptylaminecancer
N-Nitrosomethyl- n -octylamine cancer
N-Nitrosomethyl- n -nonylaminecancer
N-Nitrosomethyl- n -decylaminecancer
N-Nitrosomethyl- n -undecylaminecancer
N-Nitrosomethyl- n -dodecylaminecancer
N-Nitrosomethyl- n -tetradecylaminecancer

Organizations have 12 months to comply with the prop 65 warning requirements once a substance is added to the list; therefore products that are an exposure risk for any of these substances must be labelled by December 26, 2015.

 

 

California – Sacramento Judge Rejects ACC’s Bid to Overturn BPA Listing

BPA (Bisphenol-A) was added to the California Prop 65 list of substances. It is commonly used as an ingredient in the manufacture of polycarbonate plastic. If there are any residual unreacted quantities of BPA left in a plastic that could be an exposure risk to users, the Prop 65 warning requirement may apply.

The American Chemistry Council (ACC) has been fighting the listing of Bisphenol A (BPA) as a Proposition 65 reproductive toxicant since the California OEHHA (Office of Environmental Health Hazard Assessment)  first listed the substance in 2013 using a back-door mechanism. However, ACC received a setback in late December when a Sacramento Superior Court Judge ruled that OEHHA did not abuse its discretion when it listed BPA. The judge rejected the lawsuit brought on by the ACC to reverse the listing of BPA.

The state’s Developmental and Reproductive Toxicant Identification Committee (DART-IC) had declined to list BPA in July 2009 after reviewing relevant scientific literature. OEHHA subsequently listed BPA anyway using the authoritative body listing mechanism. It was this alternative listing mechanism that the ACC was challenging.

 

 

February 5, 2014: Final report of RoHS 2 restricted substances study – 71 priority substance areas identified

The final report delivered to the EU Commission by Umweltbundesamt on the study to review substances for potential RoHS restrictions identified and ranked a priority list of 4 substance groups, 56 substances and 11 elements. These 71 entries were assigned to eight priority levels based on hazard categories and waste management criteria.

Eight substances were identified in the highest priority category of which four were subject to detailed technical assessments and were ultimately recommended for restriction. The substances recommended for restriction are the brominated flame retardant Hexabromocyclododecane (HBCDD) and the three Phthalates (DEHP, BBP and DBP). The other four substances in the highest priority category were the Phthalate DIBP, the chlorinated flame retardant tris(2-chloroethyl)phosphate, the brominated flame retardent 2,3-dibromo-1-propanol, and Dibromoneopentyl-glycol.

Four substances were identified in the second highest priority category, comprising:

  • antimony trioxide
  • diethyl phthalate (DEP)
  • Tetrabromobisphenol A (TBBPA) and
  • medium-chain chlorinated paraffins

Tetrabromobisphenol A (TBBPA) is dear to many electronics manufacturers because of its common use in FR4 printed circuit board material and its listing as a priority substance has been particularly controversial.

Polyvinylchloride (PVC) (CAS# 9002-86-2) is the lone substance in the third priority group. PVC is not considered to be particularly hazardous in its plastic form during the use phase of a product; however, it poses environmental challenges during waste management.

The fourth, fifth, and sixth highest priority groups include five, four, and two substances respectively:
Fourth priority group:

  • the Be-(compounds): beryllium metal and beryllium oxide (BeO)
  • the Ni-compounds: nickel sulphate and nickel sulfamate (=Nickel bis sulfamidate) and
  • Indium phosphide

Fifth Priority group:

  • di-arsenic pentoxide;
  • di-arsenic trioxide;
  • cobalt dichloride; and
  • cobalt sulfate.

Sixth Priority group:

  • cobalt metal;
  • nonylphenol.

The substances identified in the top several priorities are likely to undergo more detailed assessment for possible restriction in future RoHS reviews of Annex II (Restricted Substances). EEE manufacturers and suppliers should be monitoring the use of these substances in their products.

The report is available from the consultant’s website.

January 21, 2014: IEC 62474 replaces JIG-101 declarable substance list

The Consumer Electronics Association (CEA),  DIGITALEUROPE, and the Japanese Green Procurement Survey Standardization Initiative (JGPSSI) officially announced that the JIG-101 standard that has provided the electronics industry with a list of substances of concern since 2005 is obsolete and has been replace by the International IEC 62474 standard on materials declaration.  The press release is available on the CEA website (http://www.ce.org/News/News-Releases/Press-Releases/2013-Press-Releases/Joint-Industry-Guide-%28JIG%29-101-Transitions-to-%281%29.aspx)

December 16, 2013: Seven substances added to the EU REACH SVHC Candidate List.

The 7 substances are Cadmium sulphide, C.I. Direct Red 28, C.I. Direct Black 38, Dihexyl phthalate, Imidazolidine-2-thione (2-imidazoline-2-thiol), Lead di(acetate), and Trixylyl phosphate. Manufacturers, importers and distributors have communication obligations if any of these substances are in their products in Europe contain one of these substances above the reporting threshold.

October 22, 2013: Four substances for addition to RoHS.

A public consultation was launched on the draft technical dossiers of four substances that have been assessed for addition to  the RoHS Directive.  The four substances include the flame retardant HBCDD and the three phthalates  DEHP, BBP and DBP.  All four substances are already listed on the REACH SVHC Candidate List; however, the restriction of these substances in homogeneous materials will impose a significant challenge on the EEE industry.