29JEITA-電部第224号
October 25, 2017
Subcommittee on Electronic Components Environment
ESG Committee of Electronic Components Board

Japan Electronics and Information Technology Industries Association (JEITA)
Views on the Use of Quantitative Analysis for Demonstrating Non-Inclusion of theSpecific Phthalates Added as Restricted Substances to the EU RoHS Directive
Annex II of the EU RoHS Directive (2011/65/EU) establishing restricted substances and their maximum
concentration values was amended by the EU Commission Delegated Directive (EU) 2015/863 publishedin June 2015 and the 4 types of phthalates*1 shown below were added as restricted substances.
(Hereinafter, the 4 types of phthalates will be generically mentioned as “specific phthalates”.)
Bis(2-ethylhexyl) phthalate (DEHP)
Butyl benzyl phthalate (BBP)
Dibutyl phthalate (DBP)
Diisobutyl phthalate (DIBP)
Quantitative analysis of the restricted substances has been used as one kind of confirmation data(evidence) for ensuring conformity with the requirements of the RoHS Directive Annex II.
The views of the electronic component industry concerning its practical use to the specific phthalates
are presented below.
1. Main Applications and Subparts Including the Specific Phthalates
The specific phthalates are substances mainly used as plasticizers for organic polymeric materials.
Plasticizers are substances that have the function of softening (“plasticizing”) and giving adequate
plasticity to stiff and brittle organic polymeric materials.
Plasticization occurs when molecules of plasticizers dissolve and slip into organic polymeric materials
elongating the interstices and weakening the mutual cohesive forces of molecular chains present within.
This is similar to the principle that movement becomes easier if “rollers” are inserted between twoobjects.
From this kind of principles, plasticizers have compatibility to dissolve into the organic polymericmaterials and present useful characteristics when possessing bulky structures that elongate theinterstices of the molecular chains.
Also from the viewpoint of practical use, it is required for plasticizers to be chemically stable in a wide
range of use conditions and physically non-volatile.
The specific phthalates combine the above characteristics. Particularly typical is DEHP, which has goodcompatibility with polyvinyl chloride (PVC), cellulose nitrate, methacrylic acid, chlorinated rubber, etc. andhas been used as plasticizer in a wide variety of fields.
Furthermore, due to these characteristics, it can also be used as hydraulic oil or stable solvent underhigh temperatures.
As a special application, it can also be used as inductive oil in oil-filled capacitors.
N.B. It should be noticed that for each of the specific phthalates there are application uses and subparts
where they are included other than the ones mentioned above as the items covered in this document are
simply representative examples.
On the other hand, the specific phthalates almost do not dissolve into water, and as simple substances
do not have good affinity (wettability) with inorganic materials such as metals, glasses, ceramics, etc.
For this reason, subparts of electrical and electronic equipment (EEE) containing the specificphthalates are limited to components and materials containing organic polymers in their composition orsubparts filled with the specific phthalates in a liquid state.
2. Views on the Validity of Quantitative Analysis for Demonstrating Compatibility with the RoHS Directivefor the Specific Phthalates*2
Quantitative analysis*3 of homogeneous materials is implemented as one method to confirm thecompatibility to the RoHS Directive of materials and components that constitute EEE. Based on theresults, it can be used as evidence of compatibility by showing that the inclusion amount of the restrictedsubstances is below the maximum concentration permitted.
The use of this method is appropriate for components and materials containing organic polymers that
may intentionally include the specific phthalates in their composition as well as for subparts enclosing
organic liquids.
On the other hand, the use of quantitative analysis for demonstrating compatibility to the RoHS Directive
concerning the specific phthalates for components and materials, composed only of inorganic substancessuch as metals, glasses and ceramics*4 etc. (e.g. lead wires of leaded resistors, glass resistive elements
and ceramic substrates of chip resistors, ceramic main bodies of MLCC, etc.), which present no possibilityof intentional inclusion, cannot be claimed to effectively fulfill the function for which it is performed.
As the burden employed for the analysis implementation and management of the results does not match
their effectiveness, the electronic component industry does not recommend the quantitative analysis forthese components and materials.
Footnotes*1. In Annex II of the RoHS Directive only the substance name is mentioned.
However as the specific phthalates have a large number of different names, it is useful to utilize theCAS numbers shown in the table below for identifying the substances.
Substance
Abbreviation
CAS. No.
Bis (2-ethylhexyl) phthalate
DEHP
117-81-7
Butyl benzyl phthalate
BBP
85-68-7
Dibutyl phthalate
DBP
84-74-2
Diisobutyl phthalate
DIBP
84-69-5
European Standard EN50581 (Technical documentation for the assessment of electrical andelectronic products with respect to the restriction of hazardous substances), concerning the RoHS
Directive, can be referenced as support to this document.
*3. Methods for quantitative analysis have been standardized by IEC 62321 “Determination of certain
substances in electrotechnical products”. Similarly, quantitative analysis was standardized for thespecific phthalates by IEC 62321-8, published in March of 2017.
*2.

*4.

In the documents drafted by Environment Agency Austria (Umweltbundesamt) and the Oeko
Institut as final reports (dossiers) when examining the addition of restricted substances to the RoHS
Directive, “use in ceramics of electronic components” was mentioned as an application of thespecific phthalates. However, this is used in molding applications of ceramics in the manufacturing
process before firing, and as specific phthalates are ultimately burnt during the firing/sintering
process, they do not remain in the product.

Reference Notes(i) It is known that the specific phthalates have migration characteristics, and therefore unintentional
inclusion by mixing, contamination, etc. is easier to occur than for the original restricted substancesof the RoHS Directive.
The electronic component industry considers that the detection and prevention of the above isrealized through the Quality Control structure of the entire supply chain.
(ii)

According with the literature survey carried out by the U.S. Toxicology Excellence for Risk Assessment(TERA) concerning four specific resins, namely, polypropylene (PP), polyethylene (PE), high-impact
polystyrene (HIPS), acrylonitrile butadiene styrene (ABS), it has been found that there are no applicationsof the specific phthalates involving those resins.
Even if we consider effects of recycled material and contamination, inclusion is considered to be far below
the legal threshold (1000ppm).
https://www.cpsc.gov/s3fs-public/pdfs/ReportonPhthalatesinFourPlastics.pdf