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BNST Restriction in Lubricants in EEE Approaching in March 2015

BNST (Benzenamine, N-phenyl-, Reaction Products with Styrene and 2,4,4-Trimethylpentene) has been used in lubricants in motors and other sliding mechanisms in many types of electrical and electronic products. The substance is added to lubricants as an additive that provides performance enhancements as an antioxidant, corrosion inhibitor, tarnish inhibitor, and scavenger and antiscaling agent. BNST containing lubricants may be found in some computer storage drives and other applications with a motor.

BNST was restricted in Canada under the Prohibition of Certain Toxic Substances Regulations, 2012 beginning on March 14, 2013; however, a 2 year exemption for use of BNST as an additive in lubricants has extended the use period for applications in the EEE industry.

Although the general exemption in lubricants expires on March 13, 2015, manufacturers and importers may apply for a permit to continue manufacturing and importing products and parts (such as motors) that contain BNST in the lubricant after March 2015. Even if BNST is being designed out of new products, there is still a significant challenge for OEMs that need to continue providing spare parts for the repair of existing products — there is no exemption in the regulation for spare parts. Environment Canada requires 60 working days to process a permit application; therefore they are requesting that all applications should be submitted by no later than December 1, 2014 in order to have the permit issued on time.

The permit application includes requirements for information on BNST use and plans for phasing out the substance from your products. Environment Canada has stated that applications not meeting specific minimum requirements cannot be approved.

The Prohibition Regulation is available for download from the Canada Gazette.

For support on completing and submitting a permit application, contact ECD Compliance.

Substances Recommended for EU REACH Authorisation List – September 1, 2014

On the heels of the 2014 addition to the EU REACH Annex XIV Authorisation List, the European Chemical Agency (ECHA) has recommended another 22 SVHCs for addition to the Authorisation List (see Table). This next round of proposed additions to Annex XIV is undergoing a public consultation from September 1, 2014 through November 30, 2014. The consultation provides manufacturers and suppliers with a heads-up of the substances that may be added to the Authorisation List in mid-2015.

The introductory text to the public consultation states that information provided by chemical manufacturers and importers in their substance registration dossiers were used to prioritize these substances.

Substance_Name	EC_Number	CAS_Number
1,2-Benzenedicarboxylic acid, di-C6-8-branched alkyl esters, C7-rich	276-158-1	71888-89-6
Disodium tetraborate, anhydrous	215-540-4	1330-43-4, 12179-04-3, 1303-96-4
Acetic acid, lead salt, basic	257-175-3	51404-69-4
1-bromopropane (n-propyl bromide)	203-445-0	106-94-5
4-Nonylphenol, branched and linear, ethoxylated [substances with a linear and/or branched alkyl chain with a carbon number of 9 covalently bound in position 4 to phenol, ethoxylated covering UVCB- and well-defined substances, polymers and homologues, which include any of the individual isomers and/or combinations thereof]	-	-
Bis(2-methoxyethyl) phthalate	204-212-6	117-82-8
Lead monoxide (lead oxide)	215-267-0	1317-36-8
1,2-Benzenedicarboxylic acid, di-C7-11-branched and linear alkyl esters	271-084-6	68515-42-4
Dipentyl phthalate (DPP)	205-017-9	131-18-0
Pentalead tetraoxide sulphate	235-067-7	12065-90-6
Tetraboron disodium heptaoxide, hydrate	235-541-3	12267-73-1
Anthracene oil	292-602-7	90640-80-5
Orange lead (lead tetroxide)	215-235-6	1314-41-6
Pyrochlore, antimony lead yellow	232-382-1	8012-00-8
Diboron trioxide	215-125-8	1303-86-2
N-pentyl-isopentylphthalate	-	776297-69-9
Boric acid	233-139-2, 234-343-4	10043-35-3, 11113-50-1
Diisopentylphthalate	210-088-4	605-50-5
Silicic acid, lead salt	234-363-3	11120-22-2
Tetralead trioxide sulphate	235-380-9	12202-17-4
1,2-Benzenedicarboxylic acid, dipentylester, branched and linear	284-032-2	84777-06-0
Pitch, coal tar, high temp.	266-028-2	65996-93-2

[1] ECHA public consultation on substances proposed for Authorisation under EU REACH regulation: http://echa.europa.eu/addressing-chemicals-of-concern/authorisation/recommendation-for-inclusion-in-the-authorisation-list

EU REACH – Consultation of Ten Substances for SVHC Candidate List – September 1, 2014

Dossiers for 10 SVHC proposals were submitted by EU Member States in August and are now available for public consultation on the ECHA website. Only six of the proposals are for new additions to the SVHC Candidate List. The other four dossiers are proposing modifications to the existing entries for the Phthalates DEHP, DBP, BBP, and DIBP.

The four Phthalate proposals modify the reason for SVHC inclusion to include human health and environmental hazards as endocrine disrupters.

Information about the public consultation is available on the ECHA website[1]. The consultation closes on October 16, 2014. The 10 proposals under consultation are listed in the following Table.

Substances under Consultation for REACH SVHC Candidate List

Substance_Name	EC_Number	CAS_Number	Reason_for_proposing
2-(2H-benzotriazol-2-yl)-4,6-ditertpentylphenol (UV-328)	247-384-8	25973-55-1	PBT (Article 57 d); vPvB (Article 57 e)
2-benzotriazol-2-yl-4,6-di-tert-butylphenol (UV-320)	223-346-6	3846-71-7	PBT (Article 57 d); vPvB (Article 57 e)
2-ethylhexyl 10-ethyl-4,4-dioctyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate (DOTE)	239-622-4	15571-58-1	Toxic for Reproduction (Article 57 c)
Cadmium fluoride	232-222-0	7790-79-6	Carcinogenic (Article 57 a); Mutagenic (Article 57 b); Toxic for Reproduction (Article 57 c); Equivalent level of concern having probable serious effects to human health (Article 57 f)
Cadmium sulphate	233-331-6	10124-36-4; 31119-53-6	Carcinogenic (Article 57 a); Mutagenic (article 57 b); Toxic for Reproduction (Article 57 c); Equivalent level of concern having probable serious effects to human health (Article 57 f)
Reaction mass of 2-ethylhexyl 10-ethyl-4,4-dioctyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate and 2-ethylhexyl 10-ethyl-4-[[2-[(2-ethylhexyl)oxy]-2-oxoethyl]thio]-4-octyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate (reaction mass of DOTE and MOTE)	-	-	Toxic for Reproduction (Article 57 c)
Benzyl butyl phthalate (BBP)	201-622-7	85-68-7	Equivalent level of concern having probable serious effects to human health and the environment (Article 57 f)
Bis(2-ethylhexyl) phthalate (DEHP)	204-211-0	117-81-7	Equivalent level of concern having probable serious effects to human health and the environment(Article 57 f)
Dibutyl phthalate (DBP)	201-557-4	84-74-2	Equivalent level of concern having probable serious effects to human health and the environment (Article 57 f)
Diisobutyl phthalate (DIBP)	201-553-2	84-69-5	Equivalent level of concern having probable serious effects to human health and the environment (Article 57 f)

[1] ECHA consultation website: http://echa.europa.eu/addressing-chemicals-of-concern/authorisation/substances-of-very-high-concern-identification

Nine SVHCs added to REACH Authorisation List – August 14, 2014

The European Commission has added nine substances from the SVHC Candidate List to the REACH Authorisation List (Annex XIV). As per Article 56 in the REACH regulation, substances listed in REACH Annex XIV may not be placed on the EU market (individually or in mixtures) or used in the EU after the sunset date unless the manufacturer has been granted “authorisation”. A total of 31 SVHCs are now on the authorisation list.

There are no exempted uses listed for any of the substances. Therefore all use of the substances (in the EU) after the sunset date will require authorisation. The sunset dates vary from August 22, 2017 through January 22, 2019.

Substance Name	CAS Number	Sunset date	Latest application date
Dichromium tris(chromate)	24613-89-6	22/01/2019	22/07/2017
Strontium chromate	7789-06-2	22/01/2019	22/07/2017
Pentazinc chromate octahydroxide	49663-84-5	22/01/2019	22/07/2017
Potassium hydroxyoctaoxodizincatedichromate	11103-86-9	22/01/2019	22/07/2017
2,2'-dichloro-4,4'-methylenedianiline (MOCA)	101-14-4	22/11/2017	22/05/2016
1,2-Dichloroethane (EDC)	107-06-2	22/11/2017	22/05/2016
Formaldehyde, oligomeric reaction products with aniline (technical MDA)	25214-70-4	22/08/2017	22/02/2016
Bis(2-methoxyethyl) ether (Diglyme)	111-96-6	22/08/2017	22/02/2016
Arsenic acid	7778-39-4	22/08/2017	22/02/2016

Energy Star Computers Version 6.1 Specification comes into effect on September 10, 2014

The Energy Star^tm Computer Version 6.1 specification will take effect starting on September 10th, 2014.

The quick revision from Version 6.0 to 6.1 brings slates, tablets, portable all-in-one computers, and two-in-one notebook computers into scope of the Energy Star program. “Slates” refers to app based tablets such as the Apple iPAD and Android tablets. There has been significant pressure from purchasers to develop a specification for these products given their increasing use within the work place. The Computer 6.0 specification came into effect on June 2, 2014, but didnot include these devices, so there was no way of recognizing the energy efficiency of these devices under the iconic Energy Star program.

During the develop of Version 6.1, there were several challenges with clearly defining and differentiating between the various types of computer products on the market and with identifying the appropriate energy efficiency thresholds and measurement tests for each type of computer. Energy Star is an important marketing tool for computer manufacturers, especially when selling products to institutional purchasers. There was significant feedback and emphasis from manufacturers to ensure the new product type definitons and test methods fit with emerging computer and tablet models.

A summary of changes from the 6.0 to 6.1 specification were discussed in an earlier blog post Final Draft of Energy Star Computer Specification 6.1 – June 2014

Slates and Tablets

The U.S. EPA had originally intended to use the battery charging standard (BCS) for evaluating tablets and slates; but given that the BCS program is being discontinued, the methodology was switched to using the notebook test methods and energy consumption levels to assess the tablet/slate products. In most cases, the slates/tablets will need to meet the lowest total energy consumption (TEC) specified for notebooks (category 0).

The new specification defines slates and tables as:

4) Slate/Tablet: A computing device designed for portability that meets all of the following criteria:

a) Includes an integrated display with a diagonal size greater than 6.5 inches and less than 17.4 inches;

b) Lacking an integrated, physical attached keyboard in its as-shipped configuration;

c) Includes and primarily relies on touchscreen input; (with optional keyboard);

d) Includes and primarily relies on a wireless network connection (e.g., Wi-Fi, 3G, etc.); and

e) Includes and is primarily powered by an internal battery (with connection to the mains for battery charging, not primary powering of the device).

Slate/tablet computers must support a “Display Sleep Mode” but are not required to have “System Sleep Mode”, “Wake on LAN”, or “Wake Management” functionality that is required for most other types of computers. Slates and tablets generally have a very low power long idle mode that is intended to minimize energy consumption and maximize batter life when the product is not being used. Section 3.6 of the Version 6.1 specification provides the technical energy consumption requirements for slates/tablets and portable all-in-one computers. In general, slates/tablets must meet the energy consumption requirements specified for notebook computers in section 3.5 and portable all-in-one computers must meet the energy consumptions requirements specified for integrated desktop computers. Manufacturers should review section 3.6 of the specification for further details.

Energy Star specifications are usually set so that only the top tier of products on the market qualify for Energy Star; however, it will be difficult to precisely anticipate how this will play out for slates and tablets. The U.S. EPA has stated that “EPA intends to further evaluate Slate/Tablet product data to inform the development of future Slate/Tablet energy consumption requirements in Version 7.0.” and “EPA has included a permanent note in this section stating that it intends to create independent Slate/Tablet requirements in Version 7.0 if the data from the Version 6.1 certification process can support sufficient differentiation of these products. EPA will also monitor other sources of product energy performance, such as CEC battery charger data, to help inform future Version 7.0 development.”

Products already included in the 6.0 Specification

The 6.1 specification does not change any of the definitions or energy efficiency requirements for the desktop, notebook and other computers that were already within the scope of the 6.0 specification.

Additional Requirements of Energy Star

The Energy Star specification also requires that products meet certain other design for environment provisions such as substance restrictions and appropriate design for recyclability.

Slates/Tablets Become Eligible for EPEAT Registry

With the addition of slates and tablets to Energy Star, these products also become eligible for the EPEAT^tm registry of environmentally preferable products. Many governments and other large organizations specify EPEAT registration as a mandatory requirement in their IT purchasing specifications and RFPs; therefore, EPEAT registration can be an important declaration for manufacturers and distributers.

The IEEE 1680.1 standard specifies the mandatory and optional requirements for listing a computer product on the EPEAT registry. Within this standard, Energy Star is a mandatory requirement, therefore tablets and slates have, in the past, been ineligible for EPEAT. The new Energy Star specification opens the door to additional procurement opportunities but it creates risks for manufacturers that do not register their products.

Contact ECD Compliance for information on services related to Energy Star requirements and EPEAT.

RoHS Exemptions Set to Expire in Two Years

The RoHS exemptions that are listed with no expiry date in Annex III of the EU RoHS Directive (2011/65/EU) will automatically expire on July 21, 2016 for most electrical and electronic equipment unless a manufacturer or industry association comes forward with an application to renew the exemption.

Several of the Annex III exemptions are used very broadly in electronic components and systems. This includes exemption 7(c)-I “Electrical and electronic components containing lead in a glass or ceramic other than dielectric ceramic in capacitors, e.g. piezoelectronic devices, or in a glass or ceramic matrix compound”, 7(c) -II “Lead in dielectric ceramic in capacitors for a rated voltage of 125 V AC or 250 V DC or higher” and the 6(a), 6(b), and 6(c) exemptions that allow lead to be used in certain metal alloys.

Lead in Communication Products and Servers
For communication equipment and computer server, exemption 7(b) “Lead in solders for servers, storage and storage array systems, network infrastructure equipment for switching, signaling, transmission, and network management for telecommunications” is still heavily used by many manufacturers, particularly for complex printed circuit boards using large BGA devices. Significantly development work has been underway over the past decade to develop new design and soldering materials and techniques to improve the long-term reliability of these products using PB-free solders. Many manufacturers have been progressively shifting their designs to Pb-free components and soldering processes. It appears that the industry (especially large OEMs) feels that this exemption may no longer be required and it may be time to allow the exemption to expire.

However, there are still numerous products on the market using Pb solders and significant design and RoHS assessment effort will be needed to bring these and successive products into RoHS compliance for 2016.

Exemption Renewal Requests
Under the original RoHS Directive, the EU Commission would initiate studies and consultations to assess each of the exemptions and determine which required renewal and which could be allowed to expire. However, under RoHS 2, responsibility for initiating this process and providing sufficient evidence for continuing an exemption has been assigned to industry. A stakeholder (manufacturer or industry association) must submit a renewal request according to RoHS 2 Article 5 (3).

The exemption renewal request must be made at least 18 months before the exemption expires. This means that requests for renewal of Annex III exemptions must be made within the next six months; otherwise the exemptions may no longer be used in Category 1-7, and 10 products. This comes directly from the RoHS 2 Directive, Article 5, paragraph 2:

Measures adopted in accordance with point (a) of paragraph 1 shall, for categories 1 to 7, 10 and 11 of Annex I, have a validity period of up to 5 years and, for categories 8 and 9 of Annex I, a validity period of up to 7 years. The validity periods are to be decided on a case-by-case basis and may be renewed.

The validity of the exemptions for Category 8 (medical devices) and 9 (monitoring and control instruments) products is 7 years from the date that the products must be RoHS compliant; therefore these may continue to leverage the exemptions for a few more years.

To track regulatory changes including the RoHS exemptions and for support on RoHS compliance process contact ECD Compliance.

RoHS Takes Effect for Medical Devices and Control and Monitoring Instruments – July 22, 2014

The EU RoHS Directive (2011/65/EU) substance restrictions and other compliance requirements come into effect today for most medical devices (category 8) and monitoring and control instruments (category 9).

Key obligations for manufacturers to implement/document Compliance Assurance System are:

draw up the required technical documentation and carry out the internal production control procedure;
ensure that their products have been designed and manufactured in accordance with the requirements for substance restrictions;
ensure that procedures are in place for series production to remain in conformity;
take all measures necessary so that the manufacturing process and its monitoring ensure compliance of the manufactured products with the technical documentation and with the requirements of the RoHS Directive;
EU declaration of conformity
register of non-conforming EEE and product recalls, and keep distributors informed;
ensure that their EEE bears a type, batch or serial number or other element allowing its identification;
materials, components and EEE which have been tested or measured in accordance with harmonised standards demonstrating compliance, shall be presumed to comply with the requirements of the RoHS Directive

The RoHS Directive obligates manufacturers to draw up ‘Technical Documentation’ that demonstrates conformity prior to placing products on the EU market. The CENELEC EN 50581 standard specifies requirements for RoHS 2 technical documentation.

Contact ECD Compliance for additional information and support on RoHS compliance or for an independent assessment or guidance on your current RoHS conformity assessment procedures.