The emergence of regulated substances is not likely to slow down anytime soon.  The European Union, on March 26, 2014, identified its list of 120 substances that EU Member States will evaluate over the next three years from 2014 to 2016. The substances are included in the EU’s Community rolling action  plan. Of these 120 substance, 53 of the substances were newly added this year — 67 of the substances were already in the plan.

The substance evaluations are spread across the 3 years: 51 substances in 2014; 48 substances in 2015; and 21 substances in 2016.

To avoid duplication of work, each substance is assigned to a specific EU member state who is responsible for performing the evaluation is accordance to the requirements specified in REACH Chapter 2 (Substance Evaluation).

The results of each evaluation will then be reviewed to assess whether the substance should be considered for the SVHC Candidate List (REACH Article 48) and/or for possible restriction in REACH Annex XVII (Article 69).  When a substance is added to the SVHC Candidate list, disclosure obligations are immediately triggered for manufacturers and importers of products that contain the substance above the threshold.  Once on the SVHC Candidate List, the substance also becomes eligible for the REACH Annex XIV Authorisation List (Article 57).

How the Plan helps industry!

This substance evaluation plan provides industry with some indication of the number and identity of substances that will be proposed for the SVHC Candidate List and Annex XVII restrictions over the next few years.  It’s always possible (even likely ) that new information will cause a few other substances to suddenly jump the priority list, but these will be rare exceptions.

Assessing which of these substances are relevant to  our industry

The plan includes  quite a few substances that  the electronics industry or supply chain may be using. Manufacturers can use this information as advance notice of potential issues with the long-term  use of these substances and the need to start to investigate alternatives.   In particular, 4 phthalates are currently identified on the 2014-2016 plan. Phthalates are commonly used  as plasticizers in PVC and other plastics.

Many of the other substances on the list are intermediate manufacturing chemicals, which ideally would not remain in a finished product; however, in many manufacturing processes, there a possibly that some unreacted quantity of the substance remains in the product.  The possibility of an unreacted substance remaining above the 0.1% w/w threshold depends on many factors including the manufacturing process, ratio of chemicals used, quality controls in manufacturing, etc.

Once the substances have been evaluated, some of the substances will be proposed for the  SVHC Candidate List and undergo an initial public consultation.  Once this happens, an industry-led International group of experts will screen the substance for potential relevanance to the electrical and electronics industry.  This group of International experts make up the validation team for the International materials declaration standard IEC 62474. IEC 62474 is an International Standard on material declaration. It includes an internationally recognized Declarable Substance List (DSL), a material declaration procedure and an XML-schema for data exchange.  The validation Team is responsible for regularly  updating the DSL  (usually twice a year).

Additional information on IEC 62474 and the validation team is available on the IEC 62474 blog at http://iec62474.rohs.ca.

For assistance in developing a roadmap of substances to conerns for your engineering teams and suppliers, contact ECD Compliance.