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.

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. 

The countries France, Belgium, Denmark, Germany, Sweden and Norway have published a guidance document  “Guidance for Suppliers of Articles”   that explains SVHC communication responsibilities based on the “Once an article, always an article” principle.  These countries have previously disagreed with the ECHA guidance that allows the 0.1% threshold to be applied based on the weight of the imported article.  The guidance document advocates a reporting threshold for SVHCs that is based on when substances/mixtures containing an SVHC are first made into an article.  According to the guidance, the information on SVHC content must be provided to downstream manufacturers and users even if the the first article (usually a part) is assembled into a larger article.   This principle will have a significant impact on the restricted substance control systems for many EEE manufacturers and distributors.

Canada issues mandatory survey notice for chemicals and products that contain any of the ten substances included in the Environment Canada list of Certain organic flame retardant substances.

First Stakeholder meeting was held in Brussels as part of the review of the “List of Restricted Substances under RoHS 2”. Several industry stakeholders expressed concern about the large number of substances being considered and that manufacturer specific voluntary restrictions  are being considered in the assessment.

Manufacturers have new obligations including Conformity Assessment Procedures, Technical Documentation, Register of non-conforming products, and identifying marks.

Manufacturers have an immediate obligation to be able to provide information on these SVHCs in their products above 0.1 percent of the article weight. The SVHC  Candidate List now contains 138 substances.  The International validation team for the IEC 62474 Declarable Substance List will begin assessing these substance to determine which substance may occur in electronics.