IEC – Study recommends International Standard with Harmonized Ecolabel Criteria

An IEC/TC111 study recommends developing an IEC International Standard with harmonized ecolabel criteria (requirements for environmental assessment of EEE products). Ecolabels are commonly used by purchasers to specify environmental performance expectations in procurement contracts for certain types of EEE equipment, especially IT equipment.
Market demand for a simple mechanism to assess the environmental performance of electronic products during procurement has led to global proliferation of ecolabels and their corresponding environmental assessment standards. These ecolabel programs are often driven by governments, product purchasers (including government purchasing), retailers, consumer groups, NGOs and the manufacturers themselves.

Standards consisting of environmental assessment criteria are used by ecolabel programs to set the requirements that must be met to earn manufacturers the right to claim and display the ecolabel. Ecolabel standards typically address environmental aspects and/or impacts that cover the full range of life cycle stages, including product design, manufacturing, transportation, use phase and end of life.

Criteria may include product requirements for reduction of hazardous substances, alternative substances assessment, materials selection, design for end of life, product longevity and life-cycle extension, energy conservation during the use phase of the product, reduction of emissions, end-of-life management, product packaging, life cycle assessment, and product carbon footprint. The criteria may also address various corporate environmental performance measures such as implementation of an environmental management system (EMS), emissions during manufacturing and transportation, sustainability reporting, organizational carbon footprint, energy management and use of renewable energy, etc.

Conflicting Requirements

The study considered environmental assessment standards that were in use in USA, Canada, EU, China, Japan, and Korea. Standards that were assessed included IEEE 1680.x (EPEAT ecolabel), Blue Angel, EU flower, TCO, Nordic Swan, several Chinese ecolabel standards, and Japan Ecomark. The group found that the environmental improvement objectives were often similar, but detailed requirements were sometimes sufficiently different that they caused conflicts in the design requirements.

EU – ECHA Proposes 18 SVHCs for REACH Authorization

The European Chemical Agency (ECHA) has proposed another 18 substances on the REACH Candidate List for addition to the Authorisation List (REACH Annex XIV). Substances that are on the Authorisation List may not be manufactured, placed on the market or used in the EU after the sunset date unless an authorisation has been granted to the manufacturer or importer for the specific use. The substances are listed in Table 2.

ECHA is accepting public comments on the proposal until December 5, 2018.  Additional information and instructions for submitting comments are available on the ECHA website[1].

Table 2: SVHCs Proposed for REACH Authorisation List

NameEC NumberCAS NumberTypical EEE Applications
4,4'-isopropylidenediphenol (bisphenol A; BPA)201-245-8May 7, 1980Antioxidant for plasticizer and PVC, ink, paint and adhesive; used as monomer in epoxy resins and plastics
1,6,7,8,9,14,15,16,17,17,18,18-Dodecachloropentacyclo[12.2.1.16,9.02,13.05,10]octadeca-7,15-diene (“Dechlorane Plus”™) covering any of its individual anti- and syn-isomers or any combination thereofFlame retardant for electric wire and cable covering material
Reaction products of 1,3,4-thiadiazolidine-2,5-dithione, formaldehyde and 4-heptylphenol, branched and linear (RP-HP) with ≥0.1% w/w 4-heptylphenol, branched and linear (4-HPbl)
2-ethylhexyl 10-ethyl-4,4-dioctyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate (DOTE)239-622-415571-58-1PVC stabilizer
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)PVC stabilizer
4,4'-bis(dimethylamino)-4''-(methylamino)trityl alcohol with ≥ 0.1% of Michler's ketone (EC No. 202-027-5) or Michler's base (EC No. 202-959-2)209-218-2561-41-1
Dioxobis(stearato)trilead235-702-812578-12-0Heat stabilizer for plastics, for example for wiring and cabling insulation.
Fatty acids, C16-18, lead salts292-966-791031-62-8Heat stabilizer for plastics, for example for wiring and cabling insulation.
Trilead dioxide phosphonate235-252-212141-20-7Heat stabilizer for PVC, for example for wiring and cabling insulation
Sulfurous acid, lead salt, dibasic263-467-162229-08-7Heat stabilizer for PVC, for example for wiring and cabling insulation
[Phthalato(2-)]dioxotrilead273-688-569011-06-9Heat stabilizer for plastics, for example for wiring and cabling insulation.
Trilead bis(carbonate) dihydroxide215-290-61319-46-6
Lead oxide sulfate234-853-712036-76-9Heat stabilizer for PVC used for wiring and cabling insulation.
Cyclohexane-1,2-dicarboxylic anhydride [1], cis-cyclohexane-1,2-dicarboxylic anhydride [2], trans-cyclohexane-1,2-dicarboxylic anhydride [3] [The individual cis- [2] and trans- [3] isomer substances and all possible combinations of the cis- and trans-isomers [1] are covered by this entry]201-604-9
236-086-3
238-009-9
85-42-7
13149-00-3
14166-21-3
Hexahydromethylphthalic anhydride [1], Hexahydro-4-methylphthalic anhydride [2], Hexahydro-1-methylphthalic anhydride [3], Hexahydro-3-methylphthalic anhydride [4] [The individual isomers [2], [3] and [4] (including their cis- and trans- stereo isomeric forms) and all possible combinations of the isomers [1] are covered by this entry]247-094-1
243-072-0
256-356-4
260-566-1

25550-51-0
19438-60-9
48122-14-1
57110-29-9

Primary use is as a hardener for epoxy resins.
Tetraethyllead201-075-478-00-2
2-methoxyethanol203-713-7109-86-4
2-ethoxyethanol203-804-1110-80-5

[1] ECHA Authorisation List proposal, https://echa.europa.eu/recommendation-for-inclusion-in-the-authorisation-list

EU – ECHA Consultation on SVHC Database Suggests Challenges Ahead

On September 20, 2018, the European Chemical Agency (ECHA) launched a consultation for input on the upcoming SVHCs in articles database.  Development and use of the database are mandated by the revised European Waste Framework Directive (WFD) that was published in June 2018 – see the July and August ECD Environmental Reports for additional background. The consultation period was very short, ending on October 9, 2018.

The supporting documentation and examples provided by ECHA during the consultation suggests that manufacturers, importers, distributers and/or retailers will be tasked to submit more detailed information on REACH SVHCs in products than previously expected by industry and may go beyond the mandatory requirements written in the regulations. This could impose a significant burden for companies, especially those with a large product portfolio.

Background

ECHA was tasked to create a database for manufacturers, importers, distributers and retailers to submit information on products that contain SVHCs above the REACH threshold – reporting will be required by the end of 2020.

ECHA provided two documents describing their current vision for the database and the information that companies will be expected to submit into the database.  The expectation is that all articles manufactured in the EU or imported into the EU and containing at least one SVHC above the REACH reporting threshold, will need to be reported in the database.

Overview of Information to be submitted

The first document “Draft scenario for a database on Candidate List substances in articles” provides background to the new database, indicating that every article or complex object that contains a Candidate List SVHC will need to be listed in the database with:

  1. Administrative/company data (related with submission management)
  2. Article/complex object data:
  3. Identification of the article/complex object
  4. Description of the article/complex object
  5. Candidate List substance data
  6. Safe use information

Proposed Technical Details

The second document “Technical supporting document” provides some technical details on the proposed reporting requirements.  The technical document provided by ECHA states that:

For complex objects, each supplier in the supply chain (in the production part of the supply chain) would need to provide the following types of additional information:

  • Identification of the complex object incorporating articles containing Candidate List substances: refers to the name of the complex object, the unique identifier (ID) and other identifiers which allow the identification of the specific complex object placed on the market;
  • Description of the complex object: refers to characteristics and/or use(s), as well as an explicit reference to each article containing Candidate List substances in the complex object;
  • Safe use information: refers to information for allowing the safe use of the complex object and to manage the risks from the incorporated articles containing Candidate List substances.

ECHA expects that a unique identifier will be assigned to the product and that information submitted by the manufacturer, etc. will indicate the specific type of product. ECHA is currently considering the:

  • United Nations Standard Products and Services Code (UNSPSC) classification scheme
  • Global Product Classification (GPC) standards, or the
  • Combined nomenclature (CN codes) (which are already being used to import products into the EU)

The document also suggests that information needs to be submitted about the type of material containing the SVHC, concentration levels, whether the article is used by consumers or by workers, etc. and for complex objects, information identifying the specific articles containing the SVHC(s) (see Figure 1).

Figure 1: Excerpt from “Technical supporting document”

 

 

 

 

 

 

 

Safe Use Information

ECHA is considering how best to communicate safe use information.  The information needs to cover all life cycle stages, including at end of life. Their preference is to use a set of standardized statements for consistency providing advice to workers, consumers, waste treatment operators.  The technical annex document provides examples of such statements, although ECHA was clearly looking for feedback from stakeholders before finalizing a strategy:

Advice to workers:

  • Wear respiratory protection in processing operations generating dust (e.g. grinding, drilling)
  • Avoid prolonged direct contact with skin during use

Advice to consumers:

  • Avoid prolonged direct contact with skin during use
  • Keep out of reach of children
  • Keep away from heat, hot surfaces, sparks, open flames
  • Do not mix with municipal waste
  • For outdoor use only

Advice to waste treatment operators:

  • Dispose of as hazardous waste
  • Waste incineration is recommended
  • ..

Data submission format 

ECHA indicated that they plan to use a harmonized EU-wide format for submission into the database and that the SVHC in article database will be based on IUCLID (the database used by the chemical industry to register substances under the REACH regulation). They’ve suggested that their existing electronic submission tool (REACH-IT) will be used. REACH-IT is fine for complex substance registrations; however, it will be unnecessarily challenging and time consuming for SVHC reporting.

Several standards committees have submitted responses to the ECHA consultation suggesting that an industry standard material declaration data format be used. Submissions were made for:  IEC 62474 (EEE), IPC-1754 (Aerospace and Defense), and IPC-1752A (EEE).

GCC – EU Comments on GCC RoHS Regulations and Responses

In response to the Gulf Cooperation Council (GCC) draft RoHS regulation, the EU submitted a few comments about the objectives of the regulation and some differences that were identified between the EU RoHS Directive and the GCC proposal.  Bahrain provided a response on behalf of the GCC Standardization Organization (GSO).

Certification Bodies

The draft GCC regulation specified a requirement for certification by an “Accepted Conformity Assessment Body” but it was unclear how an accepted body is designated.

The GSO responded that the GSO has established a “fully transparent system” for CABs qualification which is already being used for low voltage electronic equipment and toys.

“Relevant information, procedure for notification, and list of notified bodies can be reached at the following link: https://www.gso.org.sa/nb/

GSO stated that they will start to accredit Notified Bodies once the RoHS requirements are approved.

Self-Declaration vs. Certification

The EU suggested that the EU RoHS approach of manufacturer self assessment and declaration may be “less trade restrictive” than pre-market certification.

The GSO responded that they are seeking the simplest approach but that their market surveillance system is still weak, so it is too early to rely on a system based on self-declaration.

“… GSO needs first to strengthen the Market Surveillance in Member States, to establish a legal framework for producers liability and to encourage Consumer Protection Associations that contribute significantly to Market Surveillance.”

Exclusions for spare parts and other equipment

The EU noted that the draft does not include the general exclusion for spare parts for the repair and upgrade of older products.  The GSO responded that it will consider adding such a provision for spare parts to align with EU RoHS.

Alignment with EU RoHS exemptions

There are differences between the latest EU RoHS exemptions and the draft GCC RoHS. The GSO agreed to align the exemptions with EU RoHS Annex III and IV as last updated on “18 May 2018” and to include time limits on the exemptions.

Duplicate declarations by manufacturer and importer

The EU raised a concern that the requirement for similar declarations from both the manufacturer and the importer was redundant and inefficient. The GSO acknowledged that this issue has been previously raised on other regulations and the GSO is seeking with GCC member states to find a way to simplify this requirement.

Harmonized Implementation of requirements

The EU raised a desire for harmonized implementation of GCC RoHS across the GSO and its member countries. The GSO responded:

“This is the central mission of GSO, which commit and push towards a uniform implementation of GSO TRs,… “

Impact on EEE Manufacturers

The GSO commitment to align with EU RoHS on most of the technical requirements (except self-declaration) and to harmonize implementation across the GCC member states will be welcome to EEE manufacturers.  However, it appears that the certification requirement for RoHS compliance is likely to remain.

The agreement to add time limits on the exemptions to align with EU RoHS could create some challenges. History with other RoHS regulations has shown that most countries can’t maintain the exemptions as quickly as the European Commission, causing misalignment and potentially leading to old exemptions expiring without new exemptions being implemented in time. The upcoming inclusion of RoHS exemptions in the IEC62474 International standard could help regulators outside of the EU by enabling them to directly reference an International Recognized list that is maintained as up to date.

EU – Reply to China Comment on New Enforcement Proposal

China formally submitted a comment expressing concern about the proposed EU regulation that would require all manufacturers and distributors outside of Europe who sell products into Europe to have a designated EU party that is responsible for product compliance.   The European Union has now provided a response to the comment.

The China comment highlighted the complexity of current supply chains and sales distribution models, the importance of e-commerce and the challenge posed (especially to SMEs) of requiring all sellers into the EU to designate a local party for product compliance. Furthermore, the China comment suggests that some of the disclosure requirements (information about the distribution chain and the product) may violate confidential business information.  Overall, China recommends striking and amending several of the new requirements in the proposal.

In its response, the European Union stated:

“The EU carefully considered the various options to reduce the number of non-compliant products sold in the EU, in order to facilitate global supply chains without compromising on consumer safety and other requirements of public interest. The establishment of more complex or new supply chains with an increasing variety of actors should neither come at the detriment of product safety and compliance, nor should it restrict the possibility to enforce product safety and compliance requirements. The inclusion of the provision for a person responsible for compliance information was the most effective and proportionate way to achieve these policy objectives while avoiding unnecessary restrictions to trade.

The EU would like to highlight that this provision reinforces the capacity of manufacturers to communicate with market surveillance authorities.”

To address the issue that the distribution chain may be confidential information, the EU responded definitively:

“The identity of the person responsible for compliance information (which can be a legal or a natural person, at the choice of the manufacturer) cannot constitute a trade secret.”

The China comment expressed concern that the new requirements gave too much authority to enforcement bodies, implying that the enforcement bodies would abuse the information power that they are given.  This implication was not well received by the EU who (politely) responded that manufacturers and importers are already legally required to provide most of this information as technical documentation under existing regulations and that powers of enforcement are well controlled:

“The EU would like to highlight that paragraph 5 of Article 14 of the notified proposal explicitly provides that the powers of market surveillance authorities must be exercised in accordance with the principle of proportionality.”

Bottom line….  The EU thanked the Chinese for their comments but did not indicated that they would not be implementing any of the suggestions.

For the reasons specified above, the EU considers that the notified proposal is not more trade-restrictive than necessary to fulfil its legitimate policy objectives, also taking account of the risks that non-fulfilment would create. It therefore fully complies with the provisions of the TBT Agreement.

The China comment and the EU reply (along with the original posting of the proposal) are available on the EU TBT portal.

Impact to EEE Manufacturers

The EU reply suggests that they intend to follow through with the proposed rules and procedures for compliance.  EEE Manufacturers that sell products into the EU via local importers and distributers should may not only see a few additional paperwork requirements for paperwork; however, manufacturers that sell directly to end customers in the EU will need to delegate a local authority for compliance purposes.

EU – Draft Ecodesign Regulation for Servers and Data Storage Products

The European Commission has notified the WTO of a draft ecodesign regulation for servers and data storage products.  The draft regulation is the outcome of the original Lot 9 study under the Ecodesign Directive which started in 2013. It follows several years of work by the Commission, EU member state representatives, consultants, and industry consultations to develop a workable regulation.  The scope of the draft regulation is limited to specific types of servers and storage products and specifically excludes server appliances. However, the draft regulation does continue the Commission`s direction of including ecodesign requirements that go beyond just energy efficiency.

Description of content: This draft Commission Regulation sets compulsory requirements on the energy efficiency (such as minimum efficiency of the internal power supply unit) as well as on the material efficiency (such as the ability of certain components to be disassembled) of servers and data storage products. In accordance with Framework Directive 2009/125/EC, products not meeting these requirements will not be allowed to be placed on the EU market.

The draft Regulation is based on the findings of technical, environmental and economic studies which have been carried out with stakeholders from around the world.

The original intention was to implement a regulation that would cover all computer servers and storage products, but a methodology and metric that is applicable to all such products has eluded the regulator and their consultants.  As a result, the draft regulation, Article 1 (Subject matter and scope) establishes the scope as:

  1. This Regulation establishes ecodesign requirements for placing on the market and putting into service of servers and online data storage products.
  2. This Regulation shall not apply to the following products:

(a) servers intended for embedded applications;
(b) servers classified as small scale servers in terms of Regulation (EU) No 617/2013;
(c) servers with more than four processor sockets;
(d) server appliances;
(e) large servers;
(f) fully fault tolerant servers;
(g) network servers;
(h) small data storage products;
(i) large data storage products.

Definition of Server

The definition of server is provided in Article 2, Definitions as:

(1) ‘server’ means a computing product that provides services and manages networked resources for client devices, such as desktop computers, notebook computers, desktop thin clients, internet protocol telephones, smartphones, tablets, tele-communication, automated systems or other servers, primarily accessed via network connections, and not through direct user input devices, such as a keyboard or a mouse and with the following characteristics:

(a) it is designed to support server operating systems (OS) and/or hypervisors, and targeted to run user-installed enterprise applications;

(b) it supports error-correcting code and/or buffered memory (including both buffered dual in-line memory modules and buffered on board configurations);

(c) all processors have access to shared system memory and are independently visible to a single OS or hypervisor;

For clarity, Article 2 defines several other related terms such as server appliance, resilient server, large server, network server, etc.

(3) ‘server appliance’ means a server that is not intended to execute user-supplied software, delivers services through one or more networks, is typically managed through a web or command line interface and is bundled with a pre-installed OS and application software that is used to perform a dedicated function or set of tightly coupled functions.;

 Ecodesign Requirements

The technical requirements that need to be met by servers and online storage products are specified in Annex II to the regulation.

Three conformance dates are specified; the initial set of requirements need to be met by March 1, 2020, followed by stricter and/or additional requirements in 2021, 2023, and 2026.

Table 3: Compliance Dates for Ecodesign Requirements of Servers and Storage Products

Compliance DateRequirements
March 1, 2020Annex II points 1.1.1, 1.2.1, 1.2.2, 2.1, 3.1, 3.3 and 3.4
March 1, 2021Annex II point 1.2.3
January 1, 2023Annex II point 1.1.2
January 1, 2026Annex II point 1.1.3

The draft regulation specifies requirements on:

  • Power Supply Efficiency (some of the requirements align with EnergyStar and others do not)
  • Idle State Power requirements
  • Material efficiency requirements (addressing disassembly secure data deletion and firmware upgrades)
  • Information to be provided by manufacturers

Furthermore, subsection 3.3 identifies information that manufacturers, authorized representatives, and importers need to make available information on the quantity of Cobalt in batteries and neodymium in HDDs and to provide disassembly instructions for the major components.

Overall, it seems that the Commission intends to persuade manufacturers to provide a high degree of transparency with information on product efficiency to potential customers, end-users, and recyclers.

Server Efficiency

The draft regulation refers to “server efficiency” and requires a server efficiency metric to be reported. It’s defined as the ratio of performance divided by power, Article 7 on “review” suggests that a minimum requirement may be set in the future.

ECD Compliance has produced a more detailed summary of the requirements and timeline.  Please contact ECD Compliance for additional information.

EU – ECHA Development of SVHC Database

Following the amendment in June of the EU Waste Framework Directive, the European Chemical Agency (ECHA) posted a press release on July 11th acknowledging that it will develop a new database on “the presence of hazardous chemicals in articles by the end of 2019 for waste treatment operators and consumers”. Companies producing, importing or selling articles that contain REACH Candidate List SVHCs will need to submit information about the products and the SVHCs by the end of 2020.

With the metal lead (Pb) now included on the Candidate List, nearly all EEE products will need to be registered in the database. ECD Compliance will follow ECHA progress in developing the database and reporting regularly.

EU – RoHS Phthalate Restriction Starts in One Year

Manufacturers are reminded that the phthalates restrictions (DEHP, DBP, BBP, DIBP) in EEE products start to take effect in less than one year.  The date that a specific EEE product needs to comply depends on the product category as shown in Table 1. Phthalates have been commonly used in plastic materials, especially wire and cable sheathing, requiring many products to be redesigned to substitute the parts that are non-conformant.  Technical documentation files also need to be updated.

Placed on the Market

EEE products need to comply if they are “placed on the EU market” on or after the date that the restriction take effect. For imported products, “placed on the EU market”, typically refers to the import date.  If a manufacturer has a tight transition timeline for its products, it’ll be important to closely manage the inventory that is not phthalate-free to ensure that it’s placed on the market before the deadline.

Table 1: Date of phthalate restrictions based on product category

Product CategoryDate of phthalate restrictions
All EEE Categories except as specified belowJuly 22, 2019
Medical devices (Category 8)
(including in vitro medical devices)
July 22, 2021
Monitoring and control instruments (including industrial monitoring and control instruments)
(Category 9)
July 22, 2021
Toys that are already subject to restriction of DEHP, BBP, and DBP through entry 51 of Annex XVII to Regulation (EC) No 1907/2006DIBP – July 22, 2019
DEHP, BBP and DBP – n/a
Spare parts and cables for repair, reuse or upgrade of EEE that was placed on EU market before the phthalate restriction came into effectn/a

Phthalate substances and thresholds

The RoHS Directive (2011/65/EU), Annex II was amended by Delegated Directive (EU) 2015/863 to add the four phthalate substances. The substances and maximum concentration in homogeneous material are:

  • Bis(2-ethylhexyl) phthalate (DEHP) (0,1 %)
  • Butyl benzyl phthalate (BBP) (0,1 %)
  • Dibutyl phthalate (DBP) (0,1 %)
  • Diisobutyl phthalate (DIBP) (0,1 %)

Technical Documentation

The technical documentation files (as per EN 50581 or IEC 63000) will need to be updated to reflect the additional substances – even if no redesign was required, the technical documentation still needs to be updated with supplier documentation and other documentation to demonstrate that the four phthalates aren’t present.

ECD Compliance can provide support to manufacturers and suppliers in implementing IEC 63000 to develop technical document for a EEE product being imported into the EU or other jurisdictions with RoHS regulations.

EU – Ten SVHCs Added to REACH Candidate List

The European Chemical Agency (ECHA), on June 27, 2018 added ten additional substances to the EU REACH Candidate List. The new SVHC entries are listed in Table 1. The IEC 62474 Validation Team has reviewed the substances for potential uses in EEE. The typical EEE applications (where applicable) are included in the table as are general uses (provided by ECHA).  There are now a total of 191 SVHCs on the REACH Candidate List.

Table 1: Ten SVHCs Added to REACH Candidate List

NameDescriptionEC no.CAS no.General UsesTypical EEE Applications
Benzene-1,2,4-tricarboxylic acid 1,2 anhydridetrimellitic anhydride; TMA209-008-0552-30-7Used in the manufacture of esters and polymers.
Benzo[ghi]perylene205-883-8191-24-2Not registered under REACH. Normally not produced intentionally but rather occurs as a constituent or impurity in other substances.Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbers
DecamethylcyclopentasiloxaneD5208-764-9541-02-6Used in washing and cleaning products, polishes and waxes and cosmetics and personal care products.Siloxanes are monomers used to manufacture silicones. Residuals may remain in silicone polymers and copolymers.
Dicyclohexyl phthalateDCHP201-545-984-61-7Used in plastisol, PVC, rubber and plastic articles. A further use is also as a phlegmatiser and dispersing agent for formulations of organic peroxides.Plasticizer, dye, pigment, paint, ink, manufacture of adhesive, lubricant
Disodium octaborate234-541-012008-41-2Used in anti-freeze products, heat transfer fluids, lubricants and greases, and washing and cleaning products.Wooden veneer sheets and pressed wooden panels (as a constituent within the starch adhesive), as a flame retardant, as stabilizer in aminoplastic resins, and as a biocide in professional and industrial wood preservation.
DodecamethylcyclohexasiloxaneD6208-762-8540-97-6Used in washing and cleaning products, polishes and waxes, cosmetics and personal care products.Siloxanes are monomers used to manufacture silicones. They may remain as unreacted in silicone polymers and copolymers, used in many electrotechnical equipment product categories.
EthylenediamineEDA203-468-6107-15-3Used in adhesives and sealants, coating products, fillers, putties, plasters, modelling clay, pH regulators and water treatment products.
Lead231-100-47439-92-1Used in metals, welding and soldering products, metal surface treatment products, and polymers.Steel, aluminum and copper alloys, lead acid batteries, solder and other applications
OctamethylcyclotetrasiloxaneD4209-136-7556-67-2Used in washing and cleaning products, polishes and waxes and cosmetics and personal care products.Siloxanes are monomers used to manufacture silicones. They may remain as unreacted in silicone polymers and copolymers, used in many electrotechnical equipment product categories.
Terphenyl, hydrogenated262-967-761788-32-7Used as a plastic additive, solvent, in coatings/inks, in adhesives and sealants, and heat transfer fluids.Plasticizers, sealants, epoxy adhesives, paints and heat sinks

Impact on EEE manufacturers

The REACH communication obligations take effect immediately for the newly added SVHCs. Unfortunately, Given that the substance “Lead” was added, the update creates a particularly difficult challenge for EEE manufacturers who now need to disclose Lead as an SVHC.  Lead (as an element) is used in many EEE products (allowed under RoHS exemptions). Note: this specific SVHC entry is applicable to lead as a stand-alone element and not as compound and is relevant to lead in several RoHS exemptions.

The EEE Industry declarable substances list was updated on July 7, 2018 to reflect the new SVHCs that are relevant to the EEE products. Please see the article on the IEC 62474 update in IEC62474 blog http://rohs.ca/iec62474 .

EU – Sweden Proposes RoHS Restriction of MCCP

The European Commission has received a proposal from Sweden to restrict medium-chained chlorinated paraffins (MCCP) under the EU RoHS Directive.  MCCPs are one of the seven priority substances that were recently out for public consultation as part of a RoHS review.  Rather than waiting for the due course of considering MCCP under the current RoHS review, Sweden is proactively pushing for the restriction.

MCCPs are used in EEE as a flame retardant and plasticizer in certain plastic materials such as PVC used in cable sheathing.

The proposal is now with the European Commission for next steps.