4 March, 2013

Joint Position of Associations inside the Electrical Industry’s Value ChainView about SVHC*) in Glass concerning the EU-REACH Regulation= Including the Handling of the Lead Oxides and Complex Oxides Containing Lead
Added in the 8th Revision of the SVHC Candidate List =Lead oxides and Complex Oxides containing Lead, which are well known as constituents of glass, wereadded in the 8th Revision of the SVHC Candidate List of the EU REACH Regulation ((EC) No 1907/2006)(published on 19 December, 2012).
We present below the view of the Electronic Components Industry concerning the notification and informationtransmission duties based on the REACH Regulation for those constituents when included in glass.

1. View of the Electronic Components Industry concerning SVHCs
The Electronic Components Industry understands and cooperates with the EU standpoint aiming at the management
and transmission of substance risk information. It shall be noted that, in the REACH Regulation, substances called
SVHC are specified as candidate substances for “authorization” based on Article 59 (1), and are not regarded asbanned substances.

The REACH Regulation establishes requirements on notification of SVHCs to ECHA (European ChemicalsAgency) in accordance with Article 7 (2) et seqq. and information transmission of SVHCs to downstream users andconsumers in accordance with Article 33, for articles imported or manufactured within the area of the EU MemberStates. However, in the case of glass with a complex structure and composition including multiple constituents, aparticular SVHC used as constituent can become a part of the glass matrix. In this case to determine whether it isstill correspondent to an SVHC or becoming part of a new compound due to chemical and physical reactions, it isimperative to establish standardized judgment criteria.

2. View Concerning Glass in Electronic Components
In the REACH Regulation, according to EU Official Journal “Commission Regulation (EC) No. 987/2008”, glass is
one substance and not a mixture of several substances.
On the other hand, in order to communicate information on glass, when considering from its chemical structure thatglass is a solid solution of several metallic oxides in an amorphous state for which a crystal system cannot bespecified, it has become common to communicate information on composition of glass (e.g. within theInternational Material Data System of the automotive industry) in a more easy way apart from its real chemical
structure as a list of constituent metallic oxides. This information does not imply that the listed oxides themselves
exist as constituents of the glass.
*) SVHC Substance of Very high Concern

see also : http://echa.europa.eu/addressing-chemicals-of-concern/authorisation/substances-of-very-high-concern-identification

Nevertheless, there are cases when an SVHC may exist within a glass without being solved into a solid solution. In
such cases, it shall be interpreted as a mixture of glass and that particular SVHC.
3. View Concerning Lead Oxides and Complex Oxides Containing Lead Added in the 8th Revision of the SVHC
Candidate List
Based on the judgment criteria shown by the view concerning glass in general from the previous item, we present
our view concerning the handling of notification and information transmission based on the REACH Regulation forlead oxides and complex oxides containing lead.

3.1. Handling of Lead Oxide (PbO, Pb3O4)) Noted as Constituent of Glass
Chemical characteristics including risk to environment and human beings of lead oxides (PbO, Pb3O4) as
substances as such are not comparable in properties when finally integrated into the glass matrix. This glass matrix
is not a Substance of Very High Concern (SVHC). Manufacturers/importers are not obliged to communicate
information on the substance mentioned above according to Article 33 (1) and in accordance to Art. 7 (2) et seqq. ofthe REACH Regulation.

Japan Electronics Information and Technology Industries Association
Technical Committee
Subcommittee on Electronic Components
Subcommittee on Electronic Components Environmental Technology(24JEITA-電部企第 247 号)

ZVEI – Zentralverband Elektrotechnik- und Elektronikindustrie e.V.
(German electrical and electronic manufacturers' association)
Electronic Components and System