# Presentation: 496389

## Study on hazardous substances in electrical and electronic equipment, not regulated by the RoHS Directive

**Study on hazardous substances in electrical and electronic equipment, ****not regulated by the RoHS Directive**

- Expert Workshop
- Brussels
- 6 May 2008

## Background and Objectives

- RoHS Article 4 (3): “as soon as scientific evidence is available, and in accordance with the principles on chemicals policy” **EU bodies shall decide on the prohibition of other hazardous substances and the substitution thereof by more environment-friendly alternatives** which ensure at least the same level of protection for consumers
- Study shall provide the necessary support to the Commission services by investigations on:
-  Inventory of other hazardous substances in EEE
-  Risk management of hazardous substances
-  Possible Substitutes
-  Policy options for candidate substances

## Inventory of hazardous substances in EEE

- Information on hazardous substances in EEE
- Identification of high priority substances
- Allocation to electrical & electronic components
- Typical content of hazardous substances in components
- Allocation to typical EEE products
- Allocation to WEEE categories
- Annual flow of hazardous substances in EEE

## 1) Substances of very high concern (SVHC) as defined by REACH
Carcinogenic category 1 or 2;
Mutagenic category 1 or 2;
Toxic for Reproduction category 1 or 2 	(CMR);
Persistent, Bioaccumulative & Toxic  	(PBT);
very Persistent & very Bioaccumulative 	(vPvB);
Endocrine Disrupters 	(ED)

- Carcinogenic category 1 or 2;
- Mutagenic category 1 or 2;
- Toxic for Reproduction category 1 or 2 	(CMR);
- Persistent, Bioaccumulative & Toxic  	(PBT);
- very Persistent & very Bioaccumulative 	(vPvB);
- Endocrine Disrupters 	(ED)

**Criteria for selection of high priority substances (I) **

## 2) Substances found as contaminants in humans and biota raising concern regarding potential long-term harmful effects

3) Substances forming hazardous substances during the collection and treatment of EEE (e.g. during incineration)

- 3) Substances forming hazardous substances during the collection and treatment of EEE (e.g. during incineration)

**Criteria for selection of high priority substances (II)**

## Substances which fulfil one of the criteria 1 – 3 have potential to cause severe harm to humans and/or the environment

  High priority substances 

**  ****High priority substances **

**Criteria for selection of high priority substances (III)**

## 	Substances classified as dangerous according to Annex I of 	Directive 67/548, but not fulfilling criteria 1 – 3  
	and
	Substances which are already regulated by existing legislation 

have been documented but have not been further evaluated.

- 	and
- 	Substances which are already _regulated_ by existing legislation
- have been documented but have not been further evaluated.

**Criteria for selection of high priority substances (IV)**

**Risk management of high priority hazardous substances**

- 	Exposure to humans and environment and resulting risks
- 	Monitoring data in human, other biota and environmental media
- 	Relevance of EEE with regard to total consumption
- 	Availability of substitutes
- 	Identification of substances that have major impacts on 	environment and human health by combination of intrinsic 	properties and exposure
-  **Candidate substances for potential inclusion in RoHS**

**Proposed candidate substances for potential inclusion in RoHS **

## Allocation to electrical and electronic components

**Possible substitution of candidate substances****TBBP-A**

**Substitution of TBBP-A in printed circuit boards (I)**
- Substitution of TBBP-A by _non-halogenated reactive_ FR, e.g.:-	DOPO (Dihydrooxaphosphaphenantrene) and its derivates 	which are cyclic hydrogenphosphinates
- -	Poly(1,3-phenylene methylphosphonate) in combination with 	Aluminium-tri-hydroxide (ATH) or Aluminium-oxide-hydroxide 	(AOH)

**Possible substitution of candidate substances****TBBP-A**

**Substitution of TBBP-A in printed circuit boards (II)**
- Substitution of TBBP-A by _non-halogenated additive_ FR, e.g.:
- Metal phosphinates used in combination with N-synergist such as Melamine polyphosphate, with modified (phosphorus or nitrogen containing) epoxy resin or blend with other polymers
- Metal hydroxides e.g. Aluminium Trihydroxide (ATH, Al(OH)3); Alumina monohydrate (AlOOH)

**Possible substitution of candidate substances****TBBP-A**

**Substitution of TBBP-A in printed circuit boards (III)**
- Use of inherently flame-retardant, halogen-free base materials
-  -	Thermosetting plastics e.g. epoxy-novolac resins-	Thermoplastic resins e.g. PEI (Polyether Imide) and PES 	(Polyethersulfone).

**Possible substitution of candidate substances****TBBP-A**

**Substitution of TBBP-A as additive FR in ABS used for electronic enclosures (I)**
- by phosphorous based flame retardants in combination with PC/ABS and PPE/HIPS blends:
- 	Tri-phenyl phosphate (TPP)
- 	Resorcinol bis (diphenyl phosphate) (RDP)
- 	Bis-phenol A bis(diphenyl phosphate) (BDP)

**Possible substitution of candidate substances****HBCDD**

**Substitution of HBCDD as additive FR in HIPS used for electronic enclosures / housings of EEE**
- by phosphorous based flame retardants in combination with PC/ABS and PPE/HIPS blends:
- 	Tri-phenyl phosphate (TPP)
- 	Resorcinol bis (diphenyl phosphate) (RDP)
- 	Bis-phenol A bis(diphenyl phosphate) (BDP)

**Possible substitution of candidate substances****DEHP, BBP and DBP (I)**

- _Alternative plasticizers_ in PVC:
- 	adipates (esters of adipic acids: mainly Diethylhexyl adipate 	(DEHA) and Di-isononyladipat (DINA)),
- 	citrates (esters of citric acids: mainly O-acetyl tributyl citrate 	(ATBC))
- 	(organo)phosphates: Di(2-ethylhexyl)phosphat, Tri(2-ehtylhexyl) 	phosphat
- 	trimellitate: Tri-2-ehtyl-trimellitate
- 	epoxidised soybean oil

**Possible substitution of candidate substances****DEHP, BBP and DBP (II)**

- _Alternative plastics_ showing elastic properties without addition of plasticizers:
- 	Polyethylene (PE)
- 	Polypropylene (PP)
- 	Polyurethane (mostly used as PVC substituting material in non 	EEE applications)
- 	Ethyl-Vinylacetate-Copolymere (EVA)
-  For most of the flexible-PVC products alternatives free of 	plasticizers are available.

**Possible substitution of candidate substances****MCCP & SCCP**

- Only limited information available on substitutes for MCCP and SCCP.
-  further research required to identify suitable substitutes.

**Possible substitution of candidate substances****Nonylphenol ethoxylates**

- 	already been replaced in many application areas.
- 	reasonable to assume that for the remaining small-volume 	applications for EEE substitutes are available;
-  additional information is required from the manufacturers.

**Possible substitution of candidate substances****Organochlorine and organobromine compounds**

- See substitutes proposed for TBBP-A and HBCDD.
- Within this study not possible to analyse availability of substitutes for all organochlorine and organobromine compounds.
- Several manufacturers of EEE intend to phase-out brominated flame retardants (BFR) and PVC in all their applications  substitution of organohalogen compounds in EEE is possible

**RoHS versus REACH****    ****	****	****RoHS and REACH !**** **** **

- RoHS: Focus on hazardous substances in EEE as defined in Dir 67/548/EEC
- REACH: Registration, evaluation, authorisation and restriction of chemicals
- Broad scope, not focussing on specific sectors
- REACH Authorisation: related to substances of very high concern
- 3 step procedure:
- Art. 57 / Annex 13: Definition of substances of very high concern
- Art. 59: „Candidate list“
- Art.58: Priority setting for inclusion of substances in Annex XIV.
- No automatism of placing all SVHC into candidate list / into Annex XIV;
- Priority setting: includes PBT/vPvB criteria / wide dispersive use / high production
- Volume chemicals
- REACH will consider sector-specific regulations such as RoHS
- 					Coexistence of REACH and RoHS.

**Overview on possible policy options (outlined by EU Commission)**

- Not add any new justified substances under RoHS and deal with them under REACH
- Add new substances but only for certain categories of EEE in the scope of RoHS
**Add new substances for all EEE, in the scope of RoHS but with exempted applications**
**Add new substances for all EEE without exemptions at a deferred date**
- Add new justified substances under RoHS only if substitutes already available and fully investigated
- Link inclusion of substances at a given deadline (e.g. 2014) with the results of a report on the efficiency of waste (WEEE) management for removing hazardous substances from the waste stream
- Not add any new substances but introduce labelling requirements (for example certain phthalates for certain Medical Devices)
- Not add any new substances but introduce obligation for easy removability of parts containing hazardous substances

**Proposed policy options for candidate substances**** **

**Proposed policy options for candidate substances**** **

## Further proposed policy options

- For **Be and BeO** the following policy options are proposed to support the safe recycling of Be-containing EEE:
- 	Be and BeO containing EEE should be labelled; 	exempted from this labelling requirement are Be-containing alloys 	with up to 2 %w/w Be;
- 	Be and BeO containing parts (exceeding 2 %w/w Be) should be 	easily removable during dismantling of the EEE.

## Need for clarification

**Central Questions**** ****for the discussion (I)**

**Substitution**
- Do alternative technologies and/or EEE exist without the proposed candidate substances? Status of research & development. What is a feasible phase-out timeline?
- Which effects does a restriction of hazardous substances have on innovation and research with regard to use of substitutes and/or alternative technologies?

**Central Questions**** ****for the discussion (II)**

**Environmental and social impacts**
- What are the environmental (e.g. energy use, toxicity, impact on waste stream), health (e.g. occupational health) and / or consumer safety (e.g. emissions) impacts caused by substitution compared to the ones of the proposed candidates?

**Central Questions**** ****for the discussion (III)**

**Economic impacts**
- Which costs will arise through the restriction of the proposed candidate substances in the supply chain both for industry and consumers?
- Which advantages/disadvantages will the restriction of the proposed candidate substances have on the competitiveness of industry on the internal and external market?

**Central Questions**** ****for the discussion (IV)**

**Enforcement**
- Practical workability and enforceability of restrictions?
- What are the administrative costs to enforce the restrictions?

**Further proceeding**

- Clarification of open points
- Incorporation of results of expert workshop in draft final report
- Deadline for submission of additional information by experts:20 May 2008
- 	Final report: 4 June 2008