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RoHS Review Identifies Candidate Substances

RoHS Review: Candidate Substances
Directive 2002/95/EC - RoHS
Regulation EC 1907/2006 - REACH 

Article 4(3) and Article 6 of the RoHS directive require the periodic review of new scientific evidence to consider whether other hazardous substances should be added to the list of prohibited substances. The required review was prepared by the Oko-Institut e.V., which issued its final report "Study on Hazardous Substances in Electrical and Electronic Equipment, Not Regulated by the RoHS Directive" in October 2008.

Four criteria were used to identify "high priority hazardous substances"

  Substances meeting the criteria for classification as DANGEROUS per Directive 67/548/EEC
  Substances meeting the criteria for classification as substances of very high concern (SVHC) in accordance with REACH
  Substances which have been found as CONTAMINANTS in humans and biota
  Substances which can form hazardous substances during the collection and TREATMENT of electrical & electronic equipment
Fourteen substances were identified as high priority hazardous substances
  Substance Name CAS No. Recommendation
  Tetrabromo bisphenol A (TBBP-A) 79-94-7 Inclusion in RoHS
  Hexabromo-cyclododecane (HBCDD) 25637-99-4 Inclusion in RoHS
  Medium-chained chlorinated paraffins (MCCP) 85535-85-9 Voluntary phase out;
Market surveillance
  Short-chained chlorinated paraffins (SCCP) 85535-84-8 Voluntary phase out;
Market surveillance
  Bis (2-ethylhexyl) phthalate (DEHP) 117-81-7 Inclusion in RoHS
  Butylbenzyl-phthalate (BBP) 85-68-7 Inclusion in RoHS
  Dibutylphthalate (DBP) 84-74-2 Inclusion in RoHS
  Nonylphenol 4-nonylphenol, branched
Nonylphenol ethoxylates
25154-52-3
84852-15-3
9016-45-9
Voluntary phase out;
Market surveillance
  Beryllium metal 7440-41-7 Labeling
  Beryllium oxide (BeO) 1304-56-9 Labeling
  Antimony trioxide 1309-64-4 No action necessary
  Bisphenol A 80-05-7 No action necessary
  Diarsenic trioxide
arsenic trioxide
1327-53-3 No action necessary
  Dinickel trioxide 1314-06-3 No action necessary
Five substances were selected as candidate substances for inclusion in RoHS
  TBBP-A Tetrabromo bisphenol A
  HBCDD Hexabromo-cyclododecane
  DEHP Bis (2-ethylhexyl) phthalate
  BBP Butylbenzyl-phthalate
  DBP Dibutylphthalate
  Exemptions for specific applications may be requested except for HBCDD (no exemptions allowed)
  Recommended transition period is 24 months except for TBBP-A used as reactive flame retardant (36 months)
  Caveat: cannot make "robust recommendation" because documented environmental, economic and social data for substitute substances are not complete (no comprehensive risk assessments)
Rationale for not including other substances as RoHS candidate substances
  MCCPs, SCCPs and nonylphenol/nonylphenol ethoxylates are used only in small quantities or by a very limited number of manufacturers. Although they should be phased out, their inclusion is RoHS is considered to be a disproportionate response.
  Beryllium and beryllium oxide are rarely used in consumer electrical and electronic equipment. Recycling is desirable because beryllium is expensive. To support recycling, parts should be labeled and easily removable during dismantling (excludes alloys up to 2% by weight).
  PVC does not meet the criteria for classification as dangerous in accordance with Directive 67/548/EEC. The group of organobromine and organochlorine substances needs to be investigated on a case by case basis.

For information on the current status of RoHS Recast, please follow the link.

This summary of RoHS substances by Oko-Institut is designed to provide you with an accurate, easy-to-understand overview of the topic. However:
ê We have not attempted to cover the implementation issues that need to be addressed at your company or in your supply chain. For this type of assistance, please email or call us at 972-679-8996 to inquire about our services.
ê This summary does not constitute legal advice. The actual standard in the original language should be reviewed and used for all business, legal, and product compliance purposes.

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