The draft RoHS Annex II dossier for the diisobutyl phthalate (DIBP) suggests that DIBP has minimal use within EEE products. One objective of the public consultation for DIBP is to update this information based on industry responses. DIBP may be used in nearly all of the same applications as the Phthalate DBP and is commonly used as a substitute; however, it also has similar hazard properties and environmental impact. The EU Commission is obviously concerned that the restriction of DBP under RoHS will cause significantly increased use in DIBP.

If the conclusion that DIBP is not significantly used in EEE stands — or likely to be used as a substitute; there will be little justification for the EU Commission to list DIBP as a RoHS Annex II restricted substance.

The “Study for the Review of the List of Restricted Substances under RoHS2” had already recommended four substances for potential restriction under the RoHS 2 Directive (see February 5, 2014 blog post). The EU Commission has now signalled that they intend to consider a fifth substance for possible restriction by requesting a detailed assessment of the impacts of a possible restriction of diisobutyl phthalate (DIBP) in EEE. DIBP had been identified as one of eight the highest priority substances in the study. The EU Commission is concerned that the restriction of the DBP Phthalate will lead to additional use of DIBP as a substitute. However, DIBP has many of the same hazards as DBP and these hazards will become more prevalent with increased use of the substance.

The EU Commission is undertaking the new study to (1) conduct a detailed assessment of DIBP, and (2) capture additional usage data for 21 of the priority substances in EEE. The EU Commission expects the consultants to conduct Stakeholder consultations as part of the process.

The public consultation closes on April 4, 2014. The overall duration of the contract is expected to be 5 months, suggesting that the EU Commission will try to hit it’s July 22, 2014 goal for completing the review of the RoHS 2 Annex II list of restricted substances and producing a delegated act to amend the Annex.

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.

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.