24JEITA-電部企第 207 号
December 12, 2012

Japan Electronics and Information Technology Industries Association
Electronic Components Board
Electronic Components Engineering Committee
Electronic Components Environment Subcommittee

About the industry’s position relating to diboron trioxide (B2O3),
newly listed in the Seventh SVHC under the EU-REACH Regulation

Diboron trioxide (B2O3), CAS No. 1303-86-2, which is used in raw materials for glass or
ceramics (hereinafter the “glass/ceramics”), has been newly listed in the Seventh SVHC(announced June 18, 2012) under the European Union’s REACH Regulation ((EC) No
1907/2006). We present below the electronic components industry’s position relating to thetransmission of information on diboron trioxide (B2O3).

1. Methods of indicating diboron trioxide (B2O3) (CAS No. 1303-86-2)
In the field of electronic components, diboron trioxide (B2O3) is a substance which iswidely used as a raw material for glass/ceramics of protective films, resistive bodies,electrodes, and others.
Chemical compounds in raw materials, however, first become a solid solution, and then,form glass/ceramics, which are multi-constituent substances (UVCB). It is difficult toassign a specific CAS Registry Number, keyed to the substance composition, to a UVCB
substance like glass, which assumes an amorphous state with no identifiable crystal system,and ceramics, which do not always have the ingredients in fixed proportions.
In general, UVCB substances like glass/ceramics cannot be identified with a specific CAS
Number. Instead, it has been an established practice to express the constituent substances asoxides (diboron trioxides (B2O3), for example) and then describe the final UVCB as a
mixture of such oxides. We consider it important to note the fact that the oxides themselves
are not included in a UVCB although the UVCB is identified with the oxides.

Reference URL:
- Position of the Environmental Technology Board, the Glass Industry Conference of Japan
http://www.gic.jp/techno/REACH.html(Only Japanese)- JEITA Guidelines for Indicating Ceramic
http://home.jeita.or.jp/ecb/ceramic.html(Only Japanese)

2. About replies to Certificate for Non-Inclusion of SVHC and others
Since diboron trioxide (B2O3) itself is not formed in glass/ceramics of a finished electronic
component for the reason given in foregoing section No. 1, we recommend replying that it
is “Not Included.”

3. About transmission of information on chemical substances included in products
Notwithstanding foregoing section No.2, we, in many cases, still specifically list diboron
trioxide (B2O3) as a constituent as in the past in the information we transmit on anelectronic component. The reasons are given in items (1) and (2) below. Please, however,for the reason given in section No. 1, interpret such a listing as “not classified as an SVHCsubstance.”
We specifically list diboron trioxide (B2O3) in the information on chemical substances
included in a product for the following reasons:(1) Glass of a multi-constituent substance (UVCB) has no CAS Number previously
registered in entry of data into IMDS. The inclusion rates of all substances included ineach constituent material must add up to 100% (with less than 10% of wild cardcompounds) for the particular constituent material.
Reference to the oxides to describe glass is recommended in the IMDS
Recommendation.
(2) Diboron trioxide (B2O3) has always been disclosed in the past as “a constituent of anintentionally-added raw material” as required to complete organizational or industry
formats other than IMDS.

For the reasons as shown in the foregoing, reference to the constituent oxide compounds isa recognized method to describe UVCB substances. We consider this method as mostappropriate to use in the information to be transmitted relating to the UVCB substances.
The gist of our position as given here is that we will represent boron present in molded
articles as “diboron trioxide (B2O3)” in the information to be transmitted but that “diborontrioxide (B2O3)” so listed does not refer to an SVHC.

4. Future action
Diboron trioxide (B2O3) is universally used in electronic components. There are currently
numerous electronic components that cannot use alternative glass/ceramics containing nodiboron trioxide (B2O3).
We will meet the laws and regulations and take action on the transmission of information inline with the trends of the automotive, electric, electronic, and other industries.

Footnotes:- SVHC: Substances of Very High Concern. They are substances having the property ofcausing significant harm to human health or environment, and are selected to be added toREACH Annex XIV or the Candidate List referenced in Annex XIV.
- UVCB: Substances of Unknown or Variable composition, Complex reaction products or
Biological materials.
- IMDS: International Material Data System. It is a system for collecting information on,
and the substances included in, constituent materials of automobiles.
- Wild card compound: A fictitious compound (as used in reports related to an unspecifiedcompound; or as used to conceal a highly confidential substance) that is used in IMDS asa matter of convenience.