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RoHS – Methodology Manual for Restricted Substances List
According to Recital 10, of EU Directive 2011/65/EU (RoHS), the use of the following substances should be considered as a priority for the first review, which must be completed before 22 July 2014.
These substances should be reviewed periodically thereafter by the European Commission, on its own initiative or following the submission by a Member State:
- Hexabromocyclododecane (HBCDD) a Brominated Flame Retardant
- Bis (2-ethylhexyl)
- Butyl benzyl phthalate (BPP) a commonly used plasticizer
- Dibutyl phthalate (DBP) a commonly used plasticizer
A Methodology Manual (1) was developed with the purpose of providing a documented methodology for “making decisions about inclusion of substances in ANNEX II based on scientific evidence and taking into account principles established under REACH”.
Overview of the Methodology Manual under RoHS and REACH
Part I Identification of Substances
Identification of substances used in EEE, which may have negative impacts on human health, the environment or resource efficiency during WEEE management according to RoHS Article 6 (1) a, b, and c)
Part II Pre-Assessment of Substances
Part III Detailed Assessment of Substances
Detailed assessment of high priority substances with the view to a potential restriction under RoHS2
The output of applying the Methodology Manual resulted in the identification of the following substances and associated priorities. Please refer to 2nd Interim Report (2) for the complete report. Reference to this report is to point out that there are additional substances that have been identified that could be added to the substances restricted in addition to the four identified as a priority.
Priority I Substances
In total, 11 substances were found which fulfill all 3 waste criteria and the hazard properties (human health & environment)
Halogenated flame retardants
- SCCP (short chained chlorinated paraffins), C10-13
Other halogenated compounds
- Hexachlorobenzene (already listed in the Stockholm Convention (3))
Priority II Substances
In total, 4 substances were found which fulfil all 3 waste criteria and the hazard properties (human health & environment)
- Diethyl phthalate (DEP)
- MCCP (medium chained chlorinated paraffins), C14 – C17
- Tetrabromobisphenol A"
Priority III Substances
One substance could be identified in the overall priority category III:
Priority IV Substances
Five substances could be identified in the overall priority category IV:
- Nickel sulfate
- Nickel bis(sulfamidate);
- Beryllium metal
- Beryllium oxide (BeO)
- Indium phosphide
Hazardous Substances to Be Evaluated under RoHS and REACH
Public consultations (4) on the assessment of selected substances have been initiated to evaluate the first set of substances HBCDD, DEHP, BBP and DBP to be potentially included in RoHS 2, Annex II. The period of this public consultation is ended in November and stakeholders have been invited to contribute to the evaluation.
The results of the public consultation will be published in a final report on the developed methodology for identification and assessment of substances. Additionally the conclusion of the identification and assessment as well as draft recommendations for inclusion of substances in the list of restricted substances of RoHS 2 will be presented.
Having an understanding of substances which are currently being evaluated or restricted is important but it is equally important to understand the process which will be used to identify and prioritize substances for RoHS, REACH, and other emerging requirements. A supplier of substances, components, and or raw materials could identify these substances and begin the process of “Alternative Substance Assessment” or as it is sometimes identified “Green Chemistry” before the substances are actually restricted or not authorized for use. This proactive evaluation can allow a company to “get ahead” and begin to remove these substances from their products on their own timetable.
(1) Methodology for Identification and Assessment of Substances for Inclusion in the List of Restricted Substances (Annex II) under the RoHS2 Directive (http://www.umweltbundesamt.at/
(2) 2nd Interim Report - Study for the Review of the List of Restricted Substances under RoHS2 (http://www.umweltbundesamt.at/
(3) Listing of POPs in the Stockholm Convention (http://chm.pops.int/
(4) List of Restricted Substances under RoHS 2 (http://www.umweltbundesamt.at/
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