Assistance to the Commission on technological socio-economic and cost-benefit assessment related to exemptions from the substance restrictions in electrical and electronic equipment : pack 10 : final report.
Date: 2016-07-04
Institutions: Directorate-General for Environment
Subjects: EC conformity marking, directive (EU), electrical engineering, electronic waste, electronics industry, hazardous waste, market supervision, marketing standard, report, waste recycling

Assistance to the Commission on 
Technological Socio-Economic and Cost-
Benefit Assessment Related to Exemptions 
from the Substance Restrictions in Electrical 
and Electronic Equipment: Pack 10 Final 
Report 

Study to assess 2 RoHS exemption requests [#1 Cadmium in 
colour converting II-VI LEDs (<10 μg Cd per mm2 of light-emitting 
area) for use in solid state illumination or display systems (Request 
for renewal of Exemption 39 of Annex ΙV of Directive 2011/65/EU); 
#2 Cadmium in LCD Quantum Dot Light Control Films and 
Components]  

Final report 

May 2016 

 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
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EUROPEAN COMMISSION
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Assistance to the Commission on Technological 
Socio-Economic and Cost-Benefit Assessment 
Related to Exemptions from the Substance 
Restrictions in Electrical and Electronic 
Equipment: Pack 10 Final Report 

Study to assess 2 RoHS exemption requests [#1 Cadmium in colour 
converting II-VI LEDs (<10 μg Cd per mm2 of light-emitting area) for 
use in solid state illumination or display systems (Request for renewal 
of Exemption 39 of Annex ΙV of Directive 2011/65/EU); #2 Cadmium 
in LCD Quantum Dot Light Control Films and Components] 

Carl-Otto Gensch, Oeko-Institut 

Yifaat Baron, Oeko-Institut 

Markus Blepp, Oeko-Institut 

17 May 2016 

Report for the European Commission 

Prepared by Oeko-Institut e.V., Institute for Applied Ecology  

Approved by  

Carl-Otto Gensch, Oeko Institute e.V 

Adrian Gibbs, Eunomia 

(Project Director) 

(Peer Review) 

Eunomia Research & Consulting Ltd 
37 Queen Square 
Bristol 
BS1 4QS 

Tel: +44 (0)117 9172250 
Fax: +44 (0)8717 142942 

Web: www.eunomia.co.uk 

United Kingdom 

Oeko-Institut e.V. 
Freiburg Head Office 
P.O. Box 1771 

79017 Freiburg, Germany 

Acknowledgements 

Tel.:+49 (0) 761 – 4 52 95-0 

Fax +49 (0) 761 – 4 52 95-288 

Web: www.oeko.de 

We would like to express our gratitude towards stakeholders who have taken an active 
role in the contribution of information concerning the requests for exemption handled 
in the course of this project. 

Disclaimer 

Eunomia Research & Consulting and and Oeko-Institut have taken due care in the 
preparation of this report to ensure that all facts and analysis presented are as 
accurate as possible within the scope of the project. However, no guarantee is 
provided in respect of the information presented, and Eunomia Research & Consulting 
and Oeko-Institut are not responsible for decisions or actions taken on the basis of the 
content of this report. 

 
 
 
 
 
 
 
 
Executive Summary 

Under Framework Contract no. ENV.C.2/FRA/2011/0020, a consortium led by Eunomia 
Research & Consulting was requested by DG Environment of the European Commission 
to provide technical and scientific support for the evaluation of exemption requests 
under the new RoHS 2 regime. The work has been undertaken by Oeko-Institut and has 
been peer reviewed by Eunomia Research & Consulting. 

E.1.0  Approach 

The RoHS Directive 2011/65/EU entered into force on 21 July 2011 and led to the repeal 
of Directive 2002/95/EC on 3 January 2013. The Directive can be considered to have 
provided for two regimes under which exemptions could be considered, RoHS 1 (the 
former Directive 2002/95/EC) and RoHS 2 (the current Directive 2011/65/EU).  

  The scope covered by the Directive is now broader as it covers all EEE (as 

referred to in Articles 2(1) and 3(1)); 

  The former list of exemptions has been transformed in to Annex III and may 
be valid for all product categories according to the limitations listed in Article 
5(2) of the Directive. Annex IV has been added and lists exemptions specific 
to categories 8 and 9; 

  The RoHS 2 Directive includes the provision that applications for exemptions 
have to be made in accordance with Annex V. However, even if a number of 
points are already listed therein, Article 5(8) provides that a harmonised 
format, as well as comprehensive guidance – taking the situation of SMEs into 
account – shall be adopted by the Commission; and 

  The procedure and criteria for the adaptation to scientific and technical 
progress have changed and now include some additional conditions and 
points to be considered. These are detailed below. 

The new Directive details the various criteria for the adaptation of its Annexes to 
scientific and technical progress. Article 5(1)(a) details the various criteria and issues that 
must be considered for justifying the addition of an exemption to Annexes III and IV: 

  The first criterion may be seen as a threshold criterion and cross-refers to the 
REACH Regulation (1907/2006/EC). An exemption may only be granted if it 
does not weaken the environmental and health protection afforded by 
REACH;  

  Furthermore, a request for exemption must be found justifiable according to 

one of the following three conditions: 

i 

 
   
 
 
 
 
o  Substitution is scientifically or technically impracticable, meaning that 
a substitute material, or a substitute for the application in which the 
restricted substance is used, is yet to be discovered, developed and, in 
some cases, approved for use in the specific application; 

o  The reliability of a substitute is not ensured, meaning that the 

probability that EEE using the substitute will perform the required 
function without failure for a period of time comparable to that of the 
application in which the original substance is included, is lower than 
for the application itself; 

o  The negative environmental, health and consumer safety impacts of 

substitution outweigh the benefits thereof. 

  Once one of these conditions is fulfilled, the evaluation of exemptions, 

including an assessment of the duration needed, shall consider the availability 
of substitutes and the socio-economic impact of substitution, as well as 
adverse impacts on innovation, and life cycle analysis concerning the overall 
impacts of the exemption; and 

  A new aspect is that all exemptions now need to have an expiry date and that 

they can only be renewed upon submission of a new application. 

E.1.1  Revaluation of Exemptions for Cadmium Quantum 

Dot Technologies 

The current study is a revaluation of two exemption requests submitted in 2012 and 
2013, and first evaluated in 2013-2014. In December 2012 the Commission received a 
request for the renewal of Annex III exemption 39, and in May 2013 a request for a new 
Annex III exemption. The exemptions, both dealing with cadmium quantum dot (CdQD) 
applications, were both reviewed in the course of an evaluation performed in 2013-
2014. The final report was published in April 20141.   

On the 20 May 2015, the European Parliament objected to the Commission Delegated 
Act adopted on the basis of the mentioned report, claiming that the report need be 
updated2; thus, a revaluation of these requests has been performed. As the requests 
both concern the application of quantum dot technologies in EEE, a joint evaluation of 
was carried out. 

An important aspect raised in the Parliaments objection to the Delegated Act regarded 
the changes that were understood to have taken place on the market in relation to 

1 See final evaluation report here: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_IX/20140422_RoHS2_Evaluation_Ex_Req
uests_2013-1-5_final.pdf  
2 See Communication here: http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//TEXT+TA+P8-
TA-2015-0205+0+DOC+XML+V0//EN&language=EN  

ii 

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CdQD applications and in relation to Cd-free quantum-dot applications, which at the 
time of the first review were understood to not yet be available on the market. 
Therefore, at the on-set of this project, both applicants as well as a manufacturer of Cd-
free QD materials were asked to provide new information as to EEE that has become 
available on the EU market and on the global market using CdQD and Cd-free QD 
materials. The parties were also asked to provide data as to the performance of such 
applications, and as to how the technologies could be compared, when used in an end 
application. The initial information provided was then used, along with documents made 
available in the course of the 2013-2014 review, as a basis for stakeholders to review as 
part of a stakeholder consultation that took place between 30.10.2015 and 08.01.2016, 
to allow stakeholders to contribute to the ongoing revaluation. Documents contributed 
were then further reviewed to allow an evaluation of scientific progress regarding QD 
applications and their implications on the exemption requests at hand. 

E.2.0  Key Findings 

The exemption requests covered in this project and the applicants concerned, as well as 
the final recommendations and proposed expiry dates are summarised in Table E. 1. The 
reader is referred to the corresponding section of this report for more details on the 
evaluation results.  

The – not legally binding – recommendations for the requests for the renewal of 
exemption requests 2013-2 and 2013-5 were submitted to the EU Commission by Oeko-
Institut and have already been published at the EU CIRCA website on 2 June 2016. So far, 
the Commission has not adopted any revision of the Annex to Directive 2011/65/EU 
based on these recommendations.  

Table E. 1: Overview of the Exemption Requests, Associated 
Recommendations and Expiry Dates 

Wording: 

Applicant 

Recommendation: Proposed 
Exemption Wording 
Formulation 

Proposed 
Duration 

Ex. Re. 
No. 

2013-2 

2013-5 

Main Entry       Sub-Entry 

Cadmium in colour converting 
II-VI LEDs (< 10 μg Cd per mm2 
of light-emitting area) for use 
in solid state illumination or 
display systems (Request for 
renewal of exemption 39 of 
Annex III of Directive 
2011/65/EU); 
Cadmium in LCD Quantum Dot 
Light Control Films and 
Components 

Cadmium selenide in 
downshifting cadmium based 
semiconductor nanocrystal 
quantum dots for use in 
display lighting applications 
(< 0.2 μg Cd per mm2 of 
display screen area) 

An exemption 
should be 
granted for 
three years 

QD Vision, Inc. 

3M Optical Systems 
Division 

iii 

 
   
 
 
 
 
 
 
The Report includes the following Sections: 

Section  1.0: Project Set-up 

Section  2.0: Scope 

Section  3.0: Links from the Directive to the REACH Regulation 

Section ‎4.0 through ‎7.0 cover the joint revaluation of the requested exemptions 
handled in the course of this project. 

iv 

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Contents 

E.1.0  Approach ............................................................................................................ i 

E.1.1 

Revaluation of Exemptions for Cadmium Quantum Dot Technologies .............. ii 

E.2.0  Key Findings ...................................................................................................... iii 

1.0 

2.0 

3.0 

4.0 

Project Set-up .................................................................................................... 9 

Scope ................................................................................................................. 9 

Links from the Directive to the REACH Regulation ........................................... 10 

Cadmium Quantum Dots in EEE – A Joint Evaluation ....................................... 15 

4.1  Background ........................................................................................................... 16 

4.2  Description of the Requested Exemption ............................................................. 17 

5.0 

Cadmium Quantum Dots in Display Applications ............................................. 20 

5.1 

The Market Availability of Quantum Dot Displays ............................................... 20 

5.1.1  Amount of Cadmium Used under the Exemptions ......................................... 26 

5.2 

Standards and Methods for Comparing Display Performance ............................. 28 

5.3  Applicant’s Justification for Exemption ................................................................ 32 

5.4  Comparative Performance of Quantum Dot Displays .......................................... 32 

5.4.1 

Reliability of Quantum Dot Displays............................................................... 40 

5.4.2 

Environmental Arguments.............................................................................. 40 
5.4.2.1  Energy Savings and Cd Emissions ......................................................................... 40 
5.4.2.2  Toxicity .................................................................................................................. 42 
5.4.2.3  Resource Use and Recycling .................................................................................. 44 

5.4.3 

Road Map to Substitution .............................................................................. 44 

5.5 

Stakeholder Contributions .................................................................................... 45 

5.6  Critical Review ....................................................................................................... 50 

5.6.1 

REACH Compliance - Relation to the REACH Regulation ................................ 50 

5.6.2 

Introductory Note ........................................................................................... 50 

5.6.3 

Scientific and Technical Practicability of Substitution .................................... 51 

5.6.4 

Environmental Arguments.............................................................................. 57 
5.6.4.1  Energy Consumption and Reduction of Emissions ................................................ 57 
5.6.4.2  Toxicity .................................................................................................................. 59 
5.6.4.3  Resource Use and Recycling .................................................................................. 61 

v 

 
   
 
 
 
 
5.6.5 

Stakeholder Contributions .............................................................................. 62 

5.6.6 

Exemption Wording Formulation ................................................................... 64 

5.6.7 

Conclusions ..................................................................................................... 65 

6.0 

Cadmium Quantum Dots in Lighting Applications ............................................ 68 

6.1 

Technical Background ........................................................................................... 69 

6.1.1 

Standards and Methods for Comparing Lighting Performance ..................... 70 

6.2 

The Market Availability of Quantum Dot Lighting ................................................ 72 

6.3  Comparative Performance of Quantum Dot Lighting ........................................... 73 

6.3.1 

Environmental Arguments.............................................................................. 79 

6.4 

Exemption Scope and Wording Formulation ........................................................ 82 

6.5  Critical Review ....................................................................................................... 82 

6.5.1 

REACH Compliance - Relation to the REACH Regulation ................................ 82 

6.5.2 

Scientific and Technical Practicability of Substitution .................................... 82 

6.5.3 

Conclusions ..................................................................................................... 85 

7.0 

Recommendation ............................................................................................ 87 

7.1  References Exemption Request 9 ......................................................................... 88 

A.1.0  Appendix 1: Relevant REACH Regulation Entries ............................................. 94 

A.2.0  Appendix 2: Nanoco Information as to QD Alternatives for HPS Horticultural 

Lighting and for High Pressure Sodium Lighting .............................................. 108 

A.2.1  High Pressure Sodium Lighting ....................................................................... 108 

A.2.2  Horticultural Lighting ...................................................................................... 110 

vi 

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List of Tables and Figures  

Table E. 1: Overview of the Exemption Requests, Associated Recommendations and 

Expiry Dates……………………………………………………………………………………………………………. iii 

Table  3-1: Relation of REACH Categories and Lists to Other Chemical Substances .......... 12 

Table  5-1: Available QD Displays on the EU Market According to QD Vision .................... 21 

Table  5-2: Commercial Quantum-dot Based Displays According to 3M ............................ 22 

Table  5-3: Cadmium-free (above) and Cadmium-based (below) QD Displays Available in 

EU as of October 2015, According to Nanoco ............................................................. 24 

Table  5-4: 3M Estimation of Cd Placed on the EU Market through QD Applications 

Addressed in Ex. Re. 2013-5 ........................................................................................ 27 

Table  5-5: Comparison of Colour Standards Submitted by 3M ......................................... 30 

Table  5-6: 3M DMSD Measured Performance Comparison of TVs at Constant Power 

(Different Luminance and Colour) ............................................................................... 36 

Table  5-7: 3M DSD Measured and Calculated Performance Comparison at Constant 

Luminance.................................................................................................................... 37 

Table  5-8: Nanoco Comparison of Energy Efficiency of Various Displays .......................... 37 

Table  5-9: Nanoco Comparison of Colour Performance of Various Displays .................... 38 

Table  5-10: Nanoco Comparison of Colour Performance of Various Displays .................. 38 

Table  5-11: Nanoco Comparison of Colour Gamut Performance of Displays .................... 39 

Table  5-12: Comparison of Energy Consumption of Displays ............................................ 40 

Table  5-13: Nanoco’s Survey on Testing Results for CFQD® and CdSe .............................. 44 

Table  5-14: Results of Applicant's "Swap" Comparisons ................................................... 53 

Table  5-15: QD Vision Comparison of Luminance Efficiency (nits/watt) vs. Colour Gamut 

for Various Wide Colour Gamut TVs on the Market ................................................... 54 

Table  5-16: Summary of Nanoco Comparative Data for Colour Gamut Performance of 

Displays ........................................................................................................................ 55 

Table  5-17: Lifetime Emissions Reductions for CdSe QD TVs Compared to In QD TVs ..... 58 

Table  5-18: Information from ECHA Registration Database .............................................. 59 

Table  5-19: Mean Indium Content of Different Display Devices ....................................... 61 

Table  6-1: Lighting Applications Containing QDs that are Available on the EU Market .... 72 

Table  6-2: Input Efficacy Values for Calculation of Cd Emissions Reductions, for LEDs at 

3000K CCT and 90 CRI Ra & 50 CRI R9 ......................................................................... 75 

Table  6-3: Comparison of Products Available in the EU .................................................... 75 

vii 

 
   
 
 
 
 
Table  6-4: Comparison of Lighting Products with Similar CCTs, Similar to that of Daylight

 ..................................................................................................................................... 76 

Table  6-5: Comparison of a High Pressure Sodium Lamp (HPS) with an Alternative 

Developed by Nanoco.................................................................................................. 76 

Table  6-6: Expected Efficacy Improvements that can be Achieved within the Next Two 

Years in CdQD SSL ........................................................................................................ 77 

Table  6-7: Performance of two LED Lamps (with and without quantum dots) with a 

Similar Performance 60W Incandescent Lamp ........................................................... 78 

Table  6-8: Parameter Specification for Conventional LED and Cd QD LED Used in Lumiled 
LCA Comparison ........................................................................................................... 79 

Table  6-9: Expected Efficacy Improvements that can be Achieved within the Next Two 

Years in CdQD SSL ........................................................................................................ 84 

Figure  4-1: Effects of Quantum Dots Size on Spectral Output (smaller QDs Emit Shorter 

Wavelength Light when Exposed to a Blue Source) .................................................... 18 

Figure  5-1: QD Vision Comparison of Luminance Efficiency (nits/watt) vs. Colour Gamut 

for CdSe and InP Films in Samsung and Hinsense TV Models ..................................... 33 

Figure  5-2: QD Vision Comparison of Luminance Efficiency (nits/watt) vs. Colour Gamut 

for Various Wide Colour Gamut TVs on the Market ................................................... 35 

Figure  6-1: Spectrum of a Warm-white (2700K, 92 CRI) LED Containing Cd-based QDs (red 
line), vs. an LED with Conventional Red Phosphor (Green Line) at the Same Colour 
Temperature and CRI ................................................................................................... 74 

Figure  6-2: Comparison of Waste Heat and Waste Sink Weights of LED Lamps ............... 81 

viii 

17/05/2016 

 
 
 
  
1.0  Project Set-up 

Assignment of project tasks to Oeko-Institut, started 25 August 2015. The overall project 
has been led by Carl-Otto Gensch. The project team at Oeko-Institut consists of the 
technical experts Yifaat Baron and Markus Blepp. Eunomia, represented by Adrian Gibbs, 
has the role of ensuring quality management. 

2.0  Scope 

The scope of the project covers the evaluation of two requests for exemptions – one 
request for the renewal of an exemption (Ex. 39 of Annex III of the RoHS Directive) and 
one request for a new exemption.  

In the course of the project, a stakeholder consultation was conducted. The stakeholder 
consultation was launched on 30 October 2015 and held for a duration of 8 weeks, thus 
concluding on 8 January 2016.   

The specific project website was used in order to keep stakeholders informed on the 
progress of work: http://rohs.exemptions.oeko.info. The consultation held during the 
project was carried out according to the principles and requirements of the European 
Commission. Stakeholders who had registered at the website were informed through 
email notifications about new steps within the project. 

Information concerning the consultation was provided on the project website, including 
a general guidance document, the applicants’ documents for each of the exemption 
requests, results from the earlier evaluation, a specific questionnaire and a link to the EU 
CIRCA website. All non-confidential stakeholder comments, submitted during the 
consultation, were made available on the RoHS Evaluation website and on the EU 
CIRCABC website (Communication and Information Resource Centre for Administrations, 
Businesses and Citizens)3.  

The evaluation of the stakeholder contributions led to further consultation including, 
inter alia, engaging with stakeholders in further discussion, further exchanges in order to 
clarify remaining questions, cross-checking with regard to the accuracy of technical 
arguments, and checks in respect of confidentiality issues.  

The requests were evaluated according to the various criteria (cf. Section   E.1.0 for 
details). The joint evaluations of the exemption requests appear in Chapters  4.0 
through  7.0. The information provided by the applicants and by stakeholders is 

3 EU CIRCABC website: https://circabc.europa.eu (Browse categories > European Commission > 
Environment > RoHS 2014 Evaluations Review, at top left, click on "Library") 

Study to Assess RoHS Exemptions  

9 

 
 
                                                       
 
summarised in the first sections. This includes a general description of the applications 
and requested exemptions, a summary of the arguments made for justifying the 
exemption, information provided concerning possible alternatives and additional aspects 
raised by the applicants and other stakeholders. In some cases, reference is also made to 
information submitted by applicants and stakeholders in previous evaluations. The 
Critical Review follows these sections, in which the submitted information is discussed, 
to clarify how the consultants evaluate the various information and what conclusions 
and recommendations have been made. For more detail, the general requirements for 
the evaluation of exemption requests may be found in the technical specifications of the 
project. 4  

3.0  Links from the Directive to the REACH 

Regulation 

Article 5 of the RoHS 2 Directive 2011/65/EU on “Adaptation of the Annexes to scientific 
and technical progress” provides for the:  

“inclusion of materials and components of EEE for specific applications in the lists 
in Annexes III and IV, provided that such inclusion does not weaken the 
environmental and health protection afforded by Regulation (EC) No 1907/2006”.  

RoHS 2 does not further elaborate the meaning of this clause.  

Regulation (EC) No 1907/2006 regulates the safe use of chemical substances, and is 
commonly referred to as the REACH Regulation since it deals with Registration, 
Evaluation, Authorisation and Restriction of Chemical substances. REACH, for its part, 
addresses substances of concern through processes of authorisation and restriction:  

  Substances that may have serious and often irreversible effects on human 
health and the environment can be added to the candidate list to be 
identified as Substances of Very High Concern (SVHCs). Following the 
identification as SVHC, a substance may be included in the Authorisation list, 
available under Annex XIV of the REACH Regulation: “List of Substances 
Subject to Authorisation”. If a SVHC is placed on the Authorisation list, 
companies (manufacturers and importers) that wish to continue using it, or 
continue placing it on the market, must apply for an authorisation for a 
specified use. Article 22 of the REACH Regulation states that:  
“Authorisations for the placing on the market and use should be granted by 
the Commission only if the risks arising from their use are adequately 

4 Cf. under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Technical_specifications_Pack_1
0.pdf  

10 

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 

controlled, where this is possible, or the use can be justified for socio-
economic reasons and no suitable alternatives are available, which are 
economically and technically viable.” 
If the use of a substance (or compound) in specific articles, or its placement 
on the market in a certain form, poses an unacceptable risk to human health 
and/or to the environment that is not adequately controlled, the European 
Chemical Agency (ECHA) may restrict its use, or placement on the market. 
These restrictions are laid down in Annex XVII of the REACH Regulation: 
“Restrictions on the Manufacture, Placing on the Market and Use of Certain 
Dangerous Substances, Mixtures and Articles”. The provisions of the 
restriction may be made subject to total or partial bans, or other restrictions, 
based on an assessment of those risks.  

The approach adopted in this report is that once a substance has been included into the 
regulation related to authorization or restriction of substances and articles under REACH, 
the environmental and health protection afforded by REACH may be weakened in cases 
where, an exemption would be granted for these uses under the provisions of RoHS. This 
is essentially the same approach as has already been adopted for the re-evaluation of 
some existing RoHS exemptions 7(c)-IV, 30, 31 and 40,5 as well as for the evaluation of a 
range of requests assessed through previous projects in respect of RoHS 2.6 
Furthermore, substances for which an authorisation or restriction process is already 
underway are also reviewed, so that future developments may be considered where 
relevant.  

When evaluating the exemption requests, with regard to REACH compliance, we have 
checked whether the substance / or its substitutes are:  

  on the list of substances proposed for the adoption to the Candidate List (the 

Registry of Intentions); 

  on the list of substances of very high concern (SVHCs- the Candidate List); 
 
in the recommendations of substances for Annex XIV (recommended to be 
added to the Authorisation List); 
listed in REACH Annex XIV itself (The Authorization List); or 
listed in REACH Annex XVII (the List of Restrictions).  

 
 

5 See Zangl, S.; Blepp, M.; Deubzer, O. (2012) Adaptation to Scientific and Technical Progress under 
Directive 2011/65/EU - Transferability of previously reviewed exemptions to Annex III of Directive 
2011/65/EU, Final Report, Oeko-Institut e. V. and Fraunhofer IZM, February 17, 2012, 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/Rohs_V/Re-
evaluations_transfer_RoHS_I_RoHS_II_final.pdf   
6 Gensch, C., Baron, Y., Blepp, M., Deubzer, O., Manhart, A. & Moch, K. (2012) Assistance to the 
Commission on technological, socio-economic and cost-benefit assessment related to exemptions from 
the substance restrictions in electrical and electronic equipment (RoHS Directive), Final Report, Oeko-
Institut e. V. and Fraunhofer IZM, 21.12.2012 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/Rohs_V/RoHS_V_Final_report_12_Dec_2012_fi
nal.pdf 

Study to Assess RoHS Exemptions  

11 

 
 
                                                       
 
As the European Chemicals Agency (ECHA) is the driving force among regulatory 
authorities in implementing the EU's chemicals legislation, the ECHA website has been 
used as the reference point for the aforementioned lists, as well as for the exhaustive 
register of the Amendments to the REACH Legal Text.  

Table  3-1 shows the relationship between the two processes and categories. Substances 
included in the red areas may only be used when certain specifications and or conditions 
are fulfilled. 

Table ‎3-1: Relation of REACH Categories and Lists to Other Chemical 
Substances 

Chemical Substances and Compounds 

     Registry of Intentions (1) 

Candidate List (2) 

Recommendations for 
Authorisation List (3) 

Annex XIV 
Authorisation 
List (4) 

REACH Regulation 
Restriction Process  

Annex XVII 
Restriction List 
(5) 

CLP Regulation Process 
for Proposing 
Classification & 
Labelling of a Substance 

Harmonised 
Classification & 
Labelling  

The following bullet points explain in detail the above mentioned lists and where they 
can be accessed:  

  Member States Competent Authorities (MSCAs) / the European Chemicals 
Agency (ECHA), on request by the Commission, may prepare Annex XV 
dossiers for identification of Substances of Very High Concern (SVHC), Annex 
XV dossiers for proposing a harmonised Classification and Labelling, or Annex 
XV dossiers proposing restrictions. The aim of the public Registry of Intentions 
is to allow interested parties to be aware of the substances for which the 
authorities intend to submit Annex XV dossiers and, therefore, facilitates 
timely preparation of the interested parties for commenting later in the 
process. It is also important to avoid duplication of work and encourage co-
operation between Member States when preparing dossiers. Note that the 
Registry of Intentions is divided into three separate sections: listing new 
intentions; intentions still subject to the decision making process; and 
withdrawn intentions. The registry of intentions is available at the ECHA 
website at: http://echa.europa.eu/web/guest/addressing-chemicals-of-
concern/registry-of-intentions; 

12 

17/05/2016 

 
 
 
 
 
 
  The identification of a substance as a Substance of Very High Concern and its 
inclusion in the Candidate List is the first step in the authorisation procedure. 
The Candidate List is available at the ECHA website at 
http://echa.europa.eu/web/guest/candidate-list-table; 

  The last step of the procedure, prior to inclusion of a substance into Annex 
XIV (the Authorisation list), involves ECHA issuing a Recommendation of 
substances for Annex XIV. The ECHA recommendations for inclusion in the 
Authorisation List are available at the ECHA website at 
http://echa.europa.eu/web/guest/addressing-chemicals-of-
concern/authorisation/recommendation-for-inclusion-in-the-authorisation-
list/authorisation-list;  

  Once a decision is made, substances may be added to the Authorisation List 
available under Annex XIV of the REACH Regulation. The use of substances 
appearing on this list is prohibited unless an Authorisation for use in a specific 
application has been approved. The Annex can be found in the consolidated 
version of the REACH Legal Text (see below); 
In parallel, if a decision is made concerning the Restriction on the use of a 
substance in a specific article, or concerning the restriction of its provision on 
the European market, then a restriction is formulated to address the specific 
terms, and this shall be added to Annex XVII of the REACH Regulation. The 
Annex can be found in the consolidated version of the REACH Legal Text (see 
below); and 

 

  As of the 21 of April, 2016, the last amendment of the REACH Legal Text was 

dated from 13 January 2016 (Commission Regulation (EU) No 2016/26) and so 
the updated consolidated version of the REACH Legal Text, dated 03.02.2016, 
was used to check Annex XIV and XVII: The consolidated version is presented 
at the ECHA website: http://eur-lex.europa.eu/legal-
content/en/TXT/PDF/?uri=CELEX:02006R1907-20160203.  

Relevant annexes and processes related to the REACH Regulation have been cross-
checked to clarify: 

 

In what cases granting an exemption could “weaken the environmental and 
health protection afforded by Regulation (EC) No 1907/2006” (Article 5(1)(a), 
paragraph 1) 

  Where processes related to the REACH regulation should be followed to 

understand where such cases may become relevant in the future; 

In this respect, restrictions and authorisations as well as processes that may lead to their 
initiation, have been reviewed, in respect of where RoHS Annex II substances are 

Study to Assess RoHS Exemptions  

13 

 
 
mentioned (i.e. lead, mercury, cadmium, hexavalent chromium, polybrominated 
biphenyls (PBB) and polybrominated diphenyl ethers (PBDE).7  

Compiled information in this respect has been included, with short clarifications where 
relevant, in Tables 1-5, which appear in Appendix  A.1.0. The information has further 
been cross-checked in relation to the various exemptions evaluated in the course of this 
project. This has been done to clarify that the Article 5(1)(a) paragraph 1 threshold-
criteria quoted above is complied with in cases where an exemption is to be granted / its 
duration renewed/ its formulation amended/ or where it is to be revoked and 
subsequently to expire as an exemption. The considerations in this regard are addressed 
in the joint evaluation report of the exemption requests under the section entitled 
“REACH Compliance - Relation to the REACH Regulation” (Sections  5.6.1 and  6.5.1). 

7 This review currently does not address the 4 phthalates, DEHP, BBP, DBP and DIBP, which according to 
Commission Delegated Directive (EU) 2015/863 of 31 March 2015, have been added to the Annex. 
Information regarding these substances shall be added in future reviews. 

14 

17/05/2016 

 
 
 
                                                       
 
4.0  Cadmium Quantum Dots in EEE – A 

Joint Evaluation 

Abbreviations  

3M DMSD  

3M Display Materials & Systems Division 

BLU 

CCT 

Cd 

CdQD 

CdSe 

CFQD® 

CRI 

EEE 

EoL 

Ex. Re. 

FWHM  

GaN 

InP 

LCD 

LES 

Back light unit 

Correlated colour temperature 

Cadmium 

Cadmium quantum dots 

Cadmium selenide 

Cadmium-free quantum dot heavy metal-free nanoparticles from Nanoco 
Technologies Ltd 

Colour rendering index 

Electrical and Electronic Equipment 

End-of-Life 

Exemption request 

Full width at half maximum  

Gallium nitride [based LED] 

Indium phosphide 

Liquid crystal display  

Lamp efficiency  

OLED    

Organic light-emitting diode 

QD 

Quantum dots 

Rec. 2020 

International Telecommunication Union (ITU) Standard Rec. 2020 

SPD  

SSL 

TV 

UHD  

Spectral power distribution  

Solid state lighting 

Television 

Ultra-high definition 

Study to Assess RoHS Exemptions  

15 

 
 
 
 
 
 
 
 
 
 
 
 
 
4.1 

Background 

QD Vision, Inc. and 3M Optical Systems Division (or 3M Display Materials & Systems 
Division in the communication throughout the current review process) have submitted 
exemption requests No. 2013-2 and No. 2013-5: 

  Cadmium in II-VI LED Down-conversion (Ex. Re. 2013-2, applicant QD Vision, 

Inc.) 

  Cadmium in LCD Quantum Dot Light Control Films and Components (Ex. Re. 

2013-5, applicant 3M Optical Systems Division) 

The exemptions, both dealing with cadmium quantum dot applications, were evaluated 
in the course of an evaluation performed in 2013-2014. The final report was published in 
April 2014 and can be viewed here: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_IX/20140422_RoHS2_Ev
aluation_Ex_Requests_2013-1-5_final.pdf  

On the basis of the evaluation report, the European Commission (EC) decided to amend 
exemption 39 of Annex III, which currently reads as follows: 

“Cadmium in colour converting II-VI LEDs (< 10 μg Cd per mm² of light-emitting 
area) for use in solid state illumination or display systems 

 Expires on 1 July 2014” 

The EC thus prepared a delegated act draft for this purpose8, stipulating that an 
exemption with the following wording was to replace the current Ex. 399: 

8 EC (2015a), European Commission, COMMISSION DELEGATED DIRECTIVE ../.../EU of 30.1.2015 amending, 
for the purposes of adapting to technical progress, Annex III to Directive 2011/65/EU of the European 
Parliament and of the Council as regards an exemption for cadmium in illumination and display lighting 
applications, referenced as C(2015) 383 final of 30.1.2015, available under: 
http://ec.europa.eu/transparency/regdoc/rep/3/2015/EN/3-2015-383-EN-F1-1.PDF  
9 EC (2015b), European Commission, ANNEX to Commission Delegated Directive amending, for the 
purposes of adapting to technical progress, Annex III to Directive 2011/65/EU of the European Parliament 
and of the Council as regards an exemption for cadmium in illumination and display lighting applications, 
referenced as C(2015) 383 final of 30.1.2015, available under: 
http://ec.europa.eu/transparency/regdoc/rep/3/2015/EN/3-2015-383-EN-F1-1-ANNEX-1.PDF  

16 

17/05/2016 

 
 
   
 
 
 
 
 
 
                                                       
 
On the 20 May 2015, the European Parliament objected to the Commission Delegated 
act adopted on the basis of the mentioned report10, claiming that the report need be 
updated; thus a re-evaluation of these requests has been performed and is presented 
herein. 

4.2 

Description of the Requested Exemption 

A short summary of the application for which the exemptions have been requested is 
provided in this section on the basis of the information available during the 2013-2014 
review. 

QD Vision11 has explained that its requested exemption (renewal of exemption 39 of 
Annex III) is required to enable manufacturers to bring to the market a quantum dot 
down-conversion material for use in two kinds of applications: solid state lighting and 
display lighting applications. The II-VI down-conversion materials (e.g. quantum dots), 
due to their narrowband, tuneable, stable and efficient properties, will provide 
consumer products with superior performance, efficiency, and net benefit to the 
environment, for which there currently is no substitute available. QD Vision explains that 
in lighting, narrowband emission translates to warmer light with 20 - 40% greater 
efficacy12. Such products have already been placed on the market in the US. In the 
display market, narrowband emission translates to televisions, monitors, tablets and 
cell-phones that can achieve 100% of colour gamut (as defined by NTSC – see 
Section  5.1.1). This property has the added benefit of increasing light throughput 
through the display, which can in turn reduce energy consumption for identical 
perceived brightness by as much as 20%.  
3M13 explains that quantum dots (QDs) are a new class of non-naturally occurring 
materials that can be tuned to efficiently emit narrow spectral distribution light at the 
optimum wavelength for LCDs.14 QDs are semiconductor nano-crystals, on the order of 

10 EP (2015), European Parliament, European Parliament resolution of 20 May 2015 on the Commission 
delegated directive of 30 January 2015 amending, for the purposes of adapting to technical progress, 
Annex III to Directive 2011/65/EU of the European Parliament and of the Council as regards an exemption 
for cadmium in illumination and display lighting applications (C(2015)00383 – 2015/2542(DEA)), available 
under: http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//TEXT+TA+P8-TA-2015-
0205+0+DOC+XML+V0//EN&language=EN  
11 QD Vision (2013a), QD Vision original exemption request document concerning exemption request 2; 
available under: http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_IX/Request_2013-
2/20132301_NON-CONFIDENTIAL_Request_for_renewal_of_exemption_39.pdf, retrieved on 12.12.2013   
12 It was not detailed in comparison to what type of lighting applications such an efficacy advantage is 
expected and thus the consultants interpret the statement to be general in nature. 
13 3M (2013a), 3M Optical Systems Division original exemption request document concerning exemption 
request 2; available under 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_IX/Request_2013-
5/3M_QDEF_Exemption_Dossier.pdf, retrieved on 05 June 2013   
14 Quoted by 3M (2013a) as: Hartlove, J. 2011. Quantum dots unleash high-colour-gamut performance in 
LED-backlit displays. LEDs Magazine   

Study to Assess RoHS Exemptions  

17 

 
 
                                                       
 
3-7 nm in size, in which excitons (an electron and hole excited pair) are confined on all 
three spatial dimensions. The wavelength of the light output from a semiconducting 
material is dependent on the band gap between normal and excited electron energy 
states. The spatial confinement of the electrons and holes of the quantum dot materials 
leads to higher band gaps compared to the band gap of same material in bulk. As a 
result, the band gaps of the quantum dots can be changed continuously by changing 
their physical size. Quantum dots are typically synthesized via solution chemistry 
(carefully controlled precipitation processes). By controlling different synthesis 
conditions (e.g. precursor, ligand concentrations, temperature, and time of the reaction) 
QDs of different sizes can be obtained. Light emitted from quantum dots can be tuned 
across most of the visual spectrum by controlling the size of the quantum dot as it is 
fabricated. According to the applicant, thin quantum dot light control films contain 
cadmium for which substitution is currently not technically practical. Alternative LCD 
technologies give broader ranges of colours which cannot be tailored to optimum 
wavelengths.15  

Figure ‎4-1: Effects of Quantum Dots Size on Spectral Output (smaller QDs 
Emit Shorter Wavelength Light when Exposed to a Blue Source)  

Source: 3M (2013a) 

Quantum dots can be “pumped” with a blue source, such as the gallium nitride (GaN) 
LED, to emit at any wavelength beyond the pump source wavelength. The emission 
spectra of QDs have narrow line-widths and are free of “satellite” peaks, thus making 
them ideal candidates for display backlights to achieve high colour purity and increased 
system energy efficiency. QDs convert light with very high efficiency (>88% quantum 
efficiency) and with very narrow output spectral distribution of only 30 – 40nm full width 
at half maximum (FWHM). Due to their tunability, narrow spectral output distributions, 
and high quantum efficiencies, quantum dots are ideal for creating back light unit (BLU) 
light sources to increase colour gamut size and maximize LCD colour performance. 16 

15 Op. cit. 3M (2013a)   
16 Op. cit. 3M (2013a)   

18 

17/05/2016 

 
 
 
                                                       
 
QD Vision states that the net benefit to the environment, of allowing the use of 
cadmium in the mentioned applications, is a result of the system level increase in 
efficiency that is achieved using the II-VI down-conversion materials, due to their 
narrowband, tuneable, and efficient nature.17 

3M has stated in the past that the primary justification for this exemption is that only QD 
LCDs are able to achieve 100% colour gamut for all screen sizes and a secondary 
justification is that the potential substitutes have a greater negative environmental 
impact.18 
At the time of the first review, a contribution was made by Nanoco-Dow19 to the 
stakeholder consultation, providing information regarding a potential substitute – 
cadmium-free quantum dots. This substitute was explained to be a quantum-dot 
material and in that sense similar in how it could be applied in display and lighting 
applications as a possible substitute. Lack of detailed quantifiable information at the 
time did not allow an actual comparison of the two technologies. The understanding that 
articles using Cd-free QD technologies had not been placed on the market at the time of 
the first review led to a recommendation to grant a short termed exemption for Cd-QDs 
used in display applications. As it was understood that solid state lighting applications 
did not exist on the market at that time for either technologies, the consultants 
recommended not granting an exemption for the use of Cd-QDs in lighting applications.  

For additional details as to the function principles of quantum dots please refer to the 
final evaluation report of the 2013-2014 review.20 The following sections shall focus on 
information provided by the applicants and by stakeholders in the course of the current 
review. From the information and data provided by the applicants and by various 
stakeholders, it is apparent that a distinction between quantum dots in display 
applications and quantum dots in solid state lighting applications has to be made to 
facilitate the comprehension of the review and its conclusions. The report is thus 
separated into a chapter related to quantum dots in displays and a chapter related to 
quantum dots in solid state lighting. Each chapter includes a summary of available 
information of relevance to the evaluation, a critical review of the various arguments 

17 Op. cit. QD Vision (2013a) 
18 Op. cit. 3M (2013a)   
19 Nanoco-Dow (2013a), Contribution made concerning Ex. Re. 2013-2 – answers to RoHS Consultation 
Questionnaire, submitted by Nanoco Technologies Limited & Dow Electronic Materials on 06.11.2013, 
available under: http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_IX/Request_2013-
2/20131106_Nonoco_Dow_Contribution_Ex_2013-2_Response_to_RoHS_Questionnaire.pdf   
20 Baron et al. (2014), Baron, Y.; Blepp, M.; Gensch, C.-O.; Deubzer, O.; in collaboration with Hogg, D., 
Assistance to the Commission on technological, socio-economic and cost-benefit assessment  
related to exemptions from the substance restrictions in electrical and electronic equipment (RoHS  
Directive) - Pack 4, Eunomia Research & Consulting Ltd. in cooperation with Oeko-Institut e.V. & 
Fraunhofer IZM; 2014, Commissioned by: European Commission, DG Environment, Brussels, available 
under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_IX/20140422_RoHS2_Evaluation_Ex_Req
uests_2013-1-5_final.pdf 

Study to Assess RoHS Exemptions  

19 

 
 
                                                       
 
raised and final conclusions as to the justification for an exemption on the basis of the 
Article 5(1)(a) criteria. The two chapters are then followed by a recommendations 
chapter which summarises the consultants’ endorsements for each of these two 
application areas.  

5.0  Cadmium Quantum Dots in Display 

Applications 

In the 2013-2014 evaluation of these requests, the two applicants (among others) 
provided data as to the first display products made available on the market making use 
of cadmium quantum dots (CdQD). In parallel it was understood that first products 
making use of cadmium-free quantum dots, a potential substitute for CdQD based 
products, were expected to shortly be placed on the market. On this basis it was 
concluded that the availability of various QD based display products on the EU market in 
the short term, would allow a better understanding of the performance of each of the 
alternative QD materials, facilitating a more comprehensive understanding as to the 
justification of exemptions for CdQDs in display applications. The applicants and 
stakeholders have thus been requested to provide information as to changes in the 
market status of these technologies and as to their comparative performance. 
Information made available in this respect is presented in the following sections. 

The Market Availability of Quantum Dot Displays  

5.1 
QD Vision21 is a manufacturer of CdQD technologies. Products on the market using its 
technology are currently understood to use an on-edge configuration, in which the QDs 
are encapsulated in an optical tube or capillary, placed at the sides of the display. As for 
the market availability of products, QD Vision states that the availability of displays 
(monitors and televisions) is complex due to the complicated distribution practices of 
manufacturers. QD Vision provides detailed data from 20.10.2015 as to the displays 
using QDs on the global market and the EU market22, adding that at the time of writing, 
two televisions and one monitor were commercially launched. QD Vision summarises the 
displays available on the EU market at the time of writing as appears in Table  5-1. 

21 QD Vision (2015a), QD VISION Responses to Question by Oeko-Institut Regarding Exemption 39.b, 
submitted 28.10.2015, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_QD_Exs__QD_Vision_a_QD_
Vision_Response_to_Oeko-Institut_Regarding_Exemption_39.B.pdf  
22 Please see detailed data under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_QD_Exs__QD_Vision_f_QD_
Product_List_20_October_2015.pdf  

20 

17/05/2016 

 
 
                                                       
 
Table ‎5-1: Available QD Displays on the EU Market According to QD Vision 

CdSe displays available on EU market 

Current model televisions  Thomson : 55UA9806 – 55” 
Televisions to be 
launched 10-11/2015: 
Current model monitor: 
Source: QD Vision (2015) 

Hisense: based on K7100 – understood 
to be 55” 
Philips : 276E6 – 27” 

InP displays available on EU market 
Samsung UN55JS9000F – 48”-88” 

In a later communication, QD Vision23 explains that display manufacturers are not 
consistent in the way they bring their models to market. For instance, it appears that 
Hisense has decided to launch their QD-based TVs in China first, while waiting for the 
exemption process in Europe to be clarified. On the other hand, TPV (Philips) has 
introduced its QD-based monitor in all major markets, including the US and Europe. 
“Characteristically, during the period of the exemption process, we have found models 
appearing and disappearing from retail sites and online stores. We strongly believe, 
however, that many more models would come to market if the regulatory uncertainty 
around the QD exemption were resolved”. 
QD Vision24 was asked to further elaborate as to the differences in the variety of Cd QD 
displays distributed globally and within the EU and further elaborated the following. “A 
number of QD Vision’s customers and prospects have expressed concerns about shipping 
their existing or future QD TV models into the EU, due to the uncertainty around the 
status of the RoHS exemption. Since last May, QD Vision executives have been asked by 
each of our customers to present status reports on the RoHS process, suggesting keen 
interest in the results of this evaluation and substantial business implications. QD Vision 
is not aware of any other features… that would preclude them from being shipped into 
the EU. All can be adapted for operation at either 110 or 220V, all are in common screen 
sizes (55” or 65”), and all feature multi-lingual user interfaces. In addition, they are all 
offered under globally-recognized brands – TCL, Hisense, Philips, and Thomson – from 
multi-national corporations that ship products in all major markets.” 
3M DMSD 25 is a manufacturer of backlight enhancement films in the liquid crystal 
display (LCD) industry. 3M DMSD explains that it is a consumer of Quantum Dot (QD) 
materials and not a manufacturer of QD materials, currently utilizing cadmium selenide 
(CdSe) containing QDs as they provide the most energy efficient solution to achieve 

23 QD Vision (2016c), QD VISION Response to Oeko Institut Questions (2nd Round) on Rohs Exemption 39b, 
submitted 19.4.2016 
24 QD Vision (2016d), QD VISION Response to Oeko Institut Questions (3rd Round) on Rohs Exemption 39b, 
submitted 21.4.2016 
25 3M DMSD (2015), 3M Display Materials & Systems Division, Re: 1st Questionnaire Regarding CdQD 
Exemptions, submitted 26.10.2015, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_QD_Exs_3M_DMSD_QDEF_
RoHS_Excemption_1st_Questionnaire_PACK_10_20152610_.pdf  

Study to Assess RoHS Exemptions  

21 

 
 
 
 
 
                                                       
 
current and future colour standards. 3M DMSD provides the following table, 
summarising devices currently available on the market: 

Table ‎5-2: Commercial Quantum-dot Based Displays According to 3M 

Source: 3M DMSD (2015) 

3M DMSD26 explains that the life cycle of an electronic device [the period throughout 
which a device is sold on the market – consultants’ interpretation] is typically 6 to 12 
months, and it is customary with these types of electronic devices to replace models on 
a frequent basis. It is the nature of the electronic industry that models will be replaced 
with the next generation seeking to improve brightness, colour and energy efficiency. 
3M DMSD further details the following press releases anticipating additional 
implementation of Cd based QD technology:  

  AUO (large panel supplier to the industry) announced full line up of QD TV’s 

(scaling production, but end TV brands not disclosed yet): 
http://www.auo.com/?sn=107&lang=en-US&c=9&n=1775  

  Changhong QD TV: 

http://www.changhongglobal.com/egdch/1982_10022.htm  

  German article: http://www.areadvd.de/tests/ces-2015-die-tv-neuheiten-

von-changhong-uhd-curved-undquantum-dot-technologie/  

  3M and Nanosys demonstrated displays showing over 90% of the Rec. 2020 
gamut at SID [the Society for Information Display Week event] (June, 2015);  
  At IFA (September 2015 consumer electronics trade show) TCL and QD Vision 
demonstrated a TCL- branded TV that presented over 90% of the Rec. 2020 
colour gamut; 

26 Op. cit. 3M DMSD (2015) 

22 

17/05/2016 

 
 
 
                                                       
 
  Vizio announced commercial availability of first REC 2020 TV (R-series) on 

October 6, 2015. 

3M DMSD27 continues that there is also strong interest from display makers for medical 
devices to incorporate the QD technology, as the enhanced colour image is an invaluable 
asset in that market segment, allowing for better discrimination in and enhanced ability 
to read diagnostic images. The automobile industry is said to be eager to use these 
higher performing displays in their applications as they provide better daylight 
readability.  

In relation to the availability of QD materials, 3M DMSD further states that it is 
committed to utilize non-Cd based alternatives if and when they can meet customer 
requirements. However in this respect it is further stated “to date no commercially viable 
non-Cd substitutes are available for purchase on the market. Although one manufacturer 
(Samsung) has put one line of TVs on the market containing a non-Cd (indium phosphide) 
QD material, this is a captive supply used in only one line of TV. For clarity, the Samsung 
non-Cd QD material is not available for purchase by others. Aside from the single line of 
Samsung televisions, there are no other electronic displays, in any application, using non-
Cd QD solutions, and there are absolutely no non-Cd Qd materials available for purchase 
in production quantities from third parties due to repeated delays by QD manufacturers 
to bring a non-Cd solution to the market for general purchase.” In this respect, 3M DMSD 
argues that “Article 5(l)(a)(2) of Directive 2011/65/EU provides that one basis for 
granting an exemption is when the reliability of substitutes is not ensured. This criterion 
is met, because there is no available substitute on the market today for CdSe based 
QDs.”28 
3M DMSD29 claims that the performance and suitability of both non-Cd and Cd-based QD 
materials were discussed by leading producers in the industry at a QD Forum held in 
March 18, 2015 in San Francisco. At this event, based on the current demonstrated state 
of technology, it is said to have been clear that commercialized non-Cd materials have 
not demonstrated the ability to fuly meet current colour standards (DCI-P3) nor are they 
able to meet pending colour standards in an energy efficient way. QD Vision has made 
similar statements. Prior to the presentation of information that the applicants have 
provided to substantiate these claims (Section  5.4), some information is reproduced in 
Section  5.1.1 as to the various standards and methods available for comparing the 
performance of display applications. 
Nanoco Technologies30 develops and manufactures a Cd-free alternative that it explains 
to be an inorganic semiconductor alloy based on indium and including other metallic and 

27 Op. cit. 3M DMSD (2015) 
28 Op. cit. 3M DMSD (2015) 
29 Op. cit. 3M DMSD (2015) 
30 Nanoco (2015a), Nanoco Technologies, Nanoco Response to 1st Questionnaire Regarding CdQD 
Exemptions, submitted 28.10.2015, available under: 

Study to Assess RoHS Exemptions  

23 

 
 
                                                       
 
non-metallic elements. Nanoco provides data reproduced in Table  5-3 as to displays 
available on the market containing Cd-free QDs and Cd-based QDs, also stating that 
announcements have been made about one or two other Cd-based QD display products 
being launched soon in the EU, such as a Philips 27” computer monitor. 

Table ‎5-3: Cadmium-free (above) and Cadmium-based (below) QD Displays 
Available in EU as of October 2015, According to Nanoco  

Source: Nanoco (2015) 

Nanoco31 further claims that the commercial availability of Cd-free QD materials and 
components is now well established:  

  Samsung and its manufacturing partner Hansol have large scale commercial 

production capacity already operational in Korea. 

  Nanoco has commercial production of CFQD® QD32 technology in the UK. 
  Dow has built a large scale commercial plant in Korea to produce CFQD® QD 

technology. 

  Several other QD companies have announced plans for Cd-free QD supply. 
These include Nanosys who has recently stated that 40% of its sales are 
already from Cd-free QDs. 

In a later communication, Nanoco informs that the Dow plant is complete and Dow 
TREVISTA™ products using Nanoco CFQD® quantum dot technology are expected to be 
used in commercial display products this year [i.e. 2016 – consultants’ comment]. Also, 

http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_QD_Exs_Nanoco_Response_
to_RoHS_Questions_27_Oct_2015.pdf  
31 Op. cit. Nanoco (2015a) 
32 CFQD®  are cadmium-free quantum dot heavy metal-free nanoparticles from Nanoco Technologies Ltd 

24 

17/05/2016 

 
 
 
                                                                                                                                                                  
 
in order to accelerate the commercial adoption of CFQD® technology, Nanoco and Dow 
has agreed to make the Dow license non-exclusive. Nanoco is now actively working to 
launch CFQD® film products in commercial displays this year based on its own QD 
production capacity in the UK.33 
Nanoco34 also states that other cadmium-free display technologies (non-QD) include: 

  LED/phosphor technology is the most widely used for displays of all sizes. 
Phosphor and colour filter technology improves year-on-year to provide 
increasing colour gamut with acceptable energy efficiency. 

  Colour filter technology is improving, which enables LED/phosphor 

technology to achieve higher colour standards. 

  OLED technology is widely available in small screen sizes, mainly for mobile 
devices. Large TV displays are also available in increasing numbers and at 
reducing prices. Colour performance is usually very high, but energy efficiency 
is typically lower than for a comparable LED TV or Cd-free QD TV. Nanoco 
believes that manufacturing costs for large OLED screens will continue to be 
significantly higher than for LED screens for the foreseeable future. 

Nanoco35 provides information as to further alternatives to Cd-based QD colour-
converting materials including various types of Cd-free QDs emitting across the visible 
spectrum, as well as alternative technologies, such as QLED technology, which utilises 
the electroluminescent (EL) properties of QDs, OLEDs, LG’s “IPS Quantum Display” 
technology and various new non-QD high performance phosphor materials: 

  QLED - Within a QLED device, a QD layer is sandwiched between electron- 
and hole-transporting organic layers. The application of an electric field 
causes electrons and holes to move into the QD layer, where they recombine 
to emit photons. QLED technology could be used for both displays and 
backlighting. The development of QLED technology using Cd-free 
nanoparticles, including InP and CuInS2, has been reported in the literature. 
  OLED - OLED displays show high colour gamut and high contrast to give very 

good image quality. Wider adoption has been held back by high 
manufacturing costs and lower energy efficiency compared to LCD displays. 
However, this technology is continuing to improve and major companies like 
LG are committed to using it and are investing $9billion. 
IPS Quantum Display – This technology, developed by LG, uses potassium- 
and nitrogen-based compounds in combination with a blue LED. The 
technology can be used to achieve 98% of the DCI colour standard, and is 
currently available in LG G4 smartphones. 

 

33 Nanoco (2016b), Nanoco Technologies, Response to Additional Questionnaire (2nd Round)Regarding 
Cadmium QD Exemptions, submitted 20.4.2016 
34 Op. cit. Nanoco (2015a) 
35 Op. cit. Nanoco (2015a) 

Study to Assess RoHS Exemptions  

25 

 
 
                                                       
 
  High Performance Phosphors – Several new, narrow band emission 

phosphors have been developed recently. These can be used to provide 
improved CRI and R9 quality for lighting with improved energy efficiency. 
They can also provide improved colour gamut in display applications. 
Examples include: 

o  Apple recently launched a new range of monitors for their iMac 

computers that use high performance phosphors to achieve wide 
colour gamut in line with the DCI-P3 standard. 

o  TriGain™ Phosphor from GE. GE claims a 32% improvement in 

luminous efficiency at CCT of 4000K compared to a conventional high 
CRI LED. This uses a K2SiF6:Mn4+ phosphor that is referred to by GE as 
PFS and by others as KSF. GE is also licensing TriGain for display 
applications with >90% NTSC. 

o  Sharp produces β-sialon:Eu, which is a narrow emission green 

phosphor using a rare earth doped oxy nitride (β-SiAlON:Eu2+). This 
has been used by Sharp, in conjunction with KSF red phosphor, to 
produce LEDs for displays that can achieve 107% of NTSC area (CIE 
1976) while achieving high brightness. 

o  Dexerials has used a narrow green thiogallate phosphor (SrGa2S4:Eu) 
and red sulphide phosphor (CaS:Eu) to make a film for displays with 
90% NTSC. 

5.1.1 

Amount of Cadmium Used under the Exemptions 

In the 2013-2014 review, the following information was presented concerning the 
amount of Cd to come onto the EU market through relevant applications. 
At the time, QD Vision36 provided estimations for the Cd content that is present in 
various products manufactured with CD QDs: 

  “Large Display (TV): Average = 500-1500ppm, 1200 ppm (μg/gram) of 

homogeneous material (quantum dots distributed in polymer matrix) typical, 
1.5mg total cadmium per unit. 

  Medium Display (Computer Monitor): Average = 1000-3000ppm, 2000 ppm 

typical, 0.2mg cadmium per unit. 

  Small display (Cellphone): Average = 1000-5000ppm, 3000 ppm typical, 10 ug 

cadmium per unit. 

  Lighting device (bulb/fixture): Average = 1000-5000ppm, 3000 ppm typical, 20 

ug cadmium per unit. 

…At 100% penetration of II-VI down-conversion materials for both lighting and 
displays, our calculations show that a maximum of 120kg of cadmium could enter 
the EU annually under this exemption. Given the current lack of product on the 

36 Op. cit. QD Vision (2013a)  

26 

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market, a reasonable product ramp projection and the proposed 2019 expiry of the 
renewed exemption, 44kg of total cadmium would enter the EU over the 2014-2019 
time period (Annex 637). This represents an average of 8.8kg per year for this time 
period…” 

3m38 estimated in the course of the past review that typically 147 kg of cadmium will be 
placed on the EU market annually by this application (i.e. QD on-surface applications). 
Table  5-4 outlines the calculations used to develop this estimation. Using the same 
numbers it is estimated that 565 kg of cadmium will be placed on the global market 
annually (i.e. the EU has a 26% share of global sales). 

Table ‎5-4: 3M Estimation of Cd Placed on the EU Market through QD 
Applications Addressed in Ex. Re. 2013-5  

Source: 3M (2013a) 

In parallel, estimations provided for the current evaluation as to the potential for energy 
savings and for subsequent savings of Cd emissions facilitate the assessment on the basis 
of the data used. 3M DMSD submitted a report prepared by Goodman39 in which among 
others the environmental impacts related to energy savings of CdQD displays was 
calculated. These calculations assumed that one 55” CdQD TV contains 39.7 mg Cd and 
stated that recent research shows that there are on average two TVs per EU household, 
and that there are 216 million households in the EU. This would mean that there are 432 
million TVs in the EU. For energy savings related to Cd QD TVs, Goodman’s calculations 
assume that 10% of the TVs currently in use in the EU would be CdQD ones.  

The consultants thus calculate that this estimation would mean that such TV’s would 
have brought 1,715 kg of Cd onto the market. It should be noted that this amount 

37 For more detail, see Annex 6 to the Applicants Dossier, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_IX/Request_2013-
2/Annex_06_Cd_calculations_summary.pdf  
38 Op. cit. 3M (2013a)  
39 Goodman (2015), EdifERA, Socio-economic assessment for Cd QD displays, submitted to stakeholder 
consultation by 3M DMSD on 7.1.2016, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Quantum_Dot_Evaluation/3
M_socio_economic_reportf.pdf  

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27 

 
 
 
                                                       
 
however is not related to an annual amount and that it should be assumed that this 
amount would be placed on the EU gradually, were 10% of all TV’s to be Cd QDs 
containing 39.5 mg Cd.  
An LCA report40 prepared on behalf of QD Vision by Engler et al. refers to an update of 
the estimate of the LCD TV market in the EU41, which calculates that “if every one of the 
estimated 57.4 million LCD TVs expected to be sold in Europe in 2015 used on-edge CdSe 
QD optical components, 86 kg of additional Cd (as CdSe QDs) would enter the EU. A more 
realistic estimate of 35 percent market penetration would lead to about 30 kg of Cd (as 
CdSe QDs) entering the EU”.  

The QD Vision estimation is understood to refer to the additional amount of Cd to be 
placed on the market per annum. It is noted from the information provided by QD Vision 
(see for example in Section  5.4.2.1), that on-edge configurations use much less Cd than 
on-surface ones (1.5 mg per display in comparison with 25-166 mg), possibly explaining 
in part the differences between 3M estimations and QD Vision ones. 

5.2 

Standards and Methods for Comparing Display 
Performance  

For the purposes of this exemption request, QD Vision42 recommends the reassessment 
be based on a direct comparison of the CdSe QD and InP QD at the level of the 
technologies, and not at the level of the applications, i.e. the qualities of the displays in 
which they are included. While the displays can give some indication of certain colour 
qualities of the QD technologies, the displays do not permit a fair and complete 
comparison of the underlying QD technologies themselves. For example, aspects of the 
display design, e.g., panel choices, optical film choices, and LED selection can all 
influence the overall system efficiency and colour. According to QD Vision, the 
parameters required for a comparison are external quantum efficiency and FWHM (“full 
width at half maximum”) of emission. If a system level comparison is also of secondary 
value, parameters of importance become: 

  Luminance efficiency (i.e. Nits/Watt) of the electronic device; and 
  % coverage of NTSC colour gamut area. 

40 Engler et al. (2015), Engler, R. E., MacDougall, L. S., Xu, J. B.,  and Willis, J., The Acta Group on behalf of 
QD Vision, Inc., L.L.C, Supplemental Statement on Life Cycle Analysis and Comparison of Cadmium (CASRN 
7440-43-9, EC 231-152-8), Cadmium Selenide (CASRN 1306-24-7, EC 215-148-3) vs. Indium Phosphide 
(CASRN 22398-80-7, EC 244-959-5) for Colour Conversion in Displays, 26.10.2015, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_QD_Exs__QD_Vision_d_QDV
_Supplemental_Life-Cycle_Analysis.pdf  
41 Referred to in Engler et al. (2015) as Risk & Policy Analysts (2015): Cadmium Selenide Quantum Dots—
RoHS Exemption Supporting Arguments. Final Report. 
42 Op. cit. QD Vision (2015a) 

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QD Vision43 explains that the Rec. 2020 specification was approved in October 2015 and 
is now an industry standard. QD Vision admits that meeting this standard is challenging 
[i.e. also for CdQDs – consultants’ comment]. But the whole point of new standards is to 
set a bar that companies must aim for, but cannot fully meet at adoption. QD Vision 
claims that it is generally understood in the industry that CdSe QDs show the promise of 
achieving Rec. 2020 colour gamut targets. QD Vision claims that there is currently no 
known technical path to Rec. 2020 for InP QDs.  
3M DMSD44 states that it is intended that upcoming ultra-high definition (UHD) 
television broadcasting will use the ITU-R Rec. 2020 standard. Additionally, 3M DMSD 
states that it is anticipated that the first UHD BluRay™ players, supporting this standard 
will be introduced to the market in early 2016. 3M DMSD also claims that this colour 
performance cannot be met by non-Cd technology at this time.  
According to 3M DMSD45, the relative parameters for enabling a comprehensive 
comparison of performance are: 

A.  Colour gamut – the ability to meet current and future colour standards; 
B.  Luminance and power - energy-efficiency; 
C.  Net positive environmental impact; 
D.  Reliability; 

3M DMSD46 provides a comparison of colour standards reproduced in Table  5-5. 

43 QD Vision (2016a), QD Vision Response to Nanoco’s Oeko Submission on Exemption 39.B, submitted 
8.1.2016, available under 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Quantum_Dot_Evaluation/Q
D_Vision_Response_to_Nanoco_Submission_FINAL_010816.pdf  
44 Op. cit. 3M DMSD (2015) 
45 Op. cit. 3M DMSD (2015) 
46 3M DMSD (2016a), 3M Display Materials & Systems Division, Re:  Pack 10 Stakeholder Comment 
Questionnaire Regarding CdQD Exemptions, submitted 7.1.2016, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Quantum_Dot_Evaluation/3
M_DMSD_Stakeholder_Contribution_PACK_10__002_.pdf  

Study to Assess RoHS Exemptions  

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Table ‎5-5: Comparison of Colour Standards Submitted by 3M 

Source: Referenced in 3M DMSD (2016a) as Noteloop, a group of cinema and broadcast designers who 
work specifically in colour for the industry. 

Nanoco47 explains that the main reason for using QD technology in display products is to 
provide improved colour gamut. However, the required colour gamut is determined by 
the colour standards used by the display and media industries, as extra colour capability 
can only be used when there is content available that has been encoded with the 
appropriate colour data. Also, it is necessary to differentiate between area and coverage. 
The colour triangle area of a display could be 110% of the area of the NTSC colour 
standard triangle, but only covers 85% of the position of the standard triangle. In this 

47 Op. cit. Nanoco (2015a) 

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17/05/2016 

 
 
 
                                                       
 
case the display would only be able to show 85% of the NTSC standard colours, so the 
85% coverage is the relevant performance measure. Nanoco states that there are three 
relevant colour standards for displays, noting that displays are usually designed to 
optimise performance against one of these standards. Because the red, blue and green 
primary colours for these standards are at different wavelengths, displays that are 
optimised for one standard may not have optimum performance when compared 
against a different standard: 

  DCI (P3) - The standard most widely referred to by leading TV manufacturers 
is DCI P3, which has been developed for digital cinema. This represents the 
highest quality media generally available. 

  sRGB (Rec. 709) - The standard most widely referred to by computer monitor 
manufacturers is sRGB, which has the same colour space as Rec. 709 that is 
also used for TVs. 

  NTSC - Generally regarded as a secondary standard, but is more commonly 

used in certain markets. 

According to Nanoco48, the secondary factor for the environmental life-cycle 
performance of displays is their energy consumption. This is regulated by the Energy 
Labelling Directive 2010/30/EU. Manufacturers must provide power consumption data 
under standard test conditions and an overall efficiency rating, so that similar size/type 
of displays can be easily compared. This is intended to encourage consumers to use 
more energy efficient products. 

In relation to the Rec. 2020 standard, Nanoco states the following: “The applicants have 
argued that only cadmium QD technology can meet colour performance standards for 
the high colour gamut display market, but this is clearly not true as the increasing sales 
of Samsung SUHD televisions show, as does Samsung’s policy commitment not to use 
cadmium based technology… the relevant current standards (sRGB, DCI-P3, Abobe RGB) 
can all be effectively achieved (>90% coverage) using 1st generation commercial 
cadmium-free QD technology. The technical performance of this technology will continue 
to improve rapidly through innovation… It is possible that standards for high colour 
displays will change in future, with Rec. 2020 being a possible contender. However, that 
standard is still in development, commercial media content is not yet available and no 
commercially available cadmium QD displays achieve >90% coverage. Rec. 2020 
performance therefore cannot be used as a test for the practicality of substitution of 
cadmium based QDs in this review.” Nanoco provides among others comparisons of the 
performance of various televisions in relation to gamut colour according to various 
standards to support this point, reproduced in Table  5-10 and Table  5-11. 

48 Op. cit. Nanoco (2015a) 

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Applicant’s‎Justification‎for‎Exemption 

5.3 
3M DMSD49 raises the following points to justify an exemption for displays: 

  There is no substitute for CdSe QDs that meet the colour quality and energy 
consumption performance metrics required by 3M’s customers in the 
electronics market. 

  Reliability: 3M’s evaluation of leading-edge, experimental non-Cd QDs 
indicates that they would result in unacceptable in-device lifetimes for 
electronics industry customers. While Samsung has made a single line of 
devices (TVs) available on the market using non-Cd based QDs, the QD 
material itself is not available for purchase by third parties, and the 
performance of the Cd free material is not equivalent with that of CdSe QDs  

  Environmental impacts: The lower energy consumption of CdSe QDs 

containing display devices50 reduces the amount of electrical energy needed, 
thereby reducing the environmental pollutants created during the electrical 
energy production process.  

  Socio-economic impacts: There is also an economic benefit for consumers. 
Devices that use less energy cause less pollution from electricity generation 
and are also cheaper to run. 

  Availability: To date no substitutes that deliver the performance required by 

their customers has been made available on the open market. 

Comparative Performance of Quantum Dot Displays 

5.4 
QD Vision51 provides a number of comparisons.  

To demonstrate the performance of the QD material, QD Vision compared two television 
sets in the following manner: 

  An InP-based QD film taken from a Samsung television (model # 

UN55JS9000F) is placed in a Hisense television (model # LED55XT910X3DUC) 
originally configured with a CdSe-based QD film from 3M; and 

  A CdSe-based QD film from 3M taken from the aforementioned Hisense 

television is installed in the aforementioned Samsung television originally 
configured with an InP-based QD film. 

QD Vision states that the results of this test (see Figure  5-1) demonstrate the dramatic 
disparity in performance between the CdSe-based QD film from 3M and the InP-based 
QD film used by Samsung. Swapping the CdSe-based QD film into the Samsung television 

49 Op. cit. 3M DMSD (2016a) 
50 Consultants’ comment - It is not specified compared to what Cd QDs exhibit lower energy consumption. 
From available data, it has been shown that this statement is relevant for display models where an InP QD 
film was swapped with a Cd QD film, however comparative data as to displays does not show that an 
advantage is always relevant when different displays are compared to each other. 
51 Op. cit. QD Vision (2015a) 

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originally configured with an InP-based film results in a 32% increase in luminance 
(explained by QD Vision to result from the higher efficiency of the CdSe-based QD film) 
and an increase in colour gamut from 91.7% to 101.3% NTSC area (explained to result 
from the narrower emission spectra from the CdSe-based QD film). QD Vision states that 
these results are supported by component-level testing, where the CdSe-based QD film 
was found to be significantly more efficient than the InP-based film (external quantum 
efficiency of 73% vs. 57%) and to have much narrower emission spectra (FWHM for 
green and red of 33 and 37nm, respectively, for the CdSe-based QD film, compared to 41 
and 55nm for the InP-based QD film). 52 

Figure ‎5-1: QD Vision Comparison of Luminance Efficiency (nits/watt) vs. 
Colour Gamut for CdSe and InP Films in Samsung and Hinsense TV Models 

Source: QD Vision (2015b) 

52 Op. cit. QD Vision (2015a) 

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QD Vision53 emphasizes that “screen quality and the ability to exceed NTSC c.q. meet 
AdobeRGB or REC 2020 is not an aesthetic aspect, but a crucial criteria for the 
assessment as it is the linchpin of performance and competitiveness and critical for 
Europe to remain current and competitive in such fields as medical diagnostics, e-
commerce and entertainment.” QD Vision claims that today’s high-end displays are able 
to produce only 30% of the colours visible to the human eye. With QD Vision QDs, it is 
said that displays approaching 60% of the human visible colour gamut are possible. A 
few key aspects raised in relation to the importance of colour gamut are: 

  Diagnostics – medical and otherwise – rely in a large part on colour. Higher 

display quality improves the precision and therefore impact of these 
technologies; 

  Audio-visual productions, whether artistic or of sports and events, have 
become consistently more popular as screen quality has improved; and 
  E-commerce is materially affected by the quality of displays as this in part 
drives their high return rate [understood in part to be a result of products 
returned following dissatisfaction with purchased product appearance – 
consultants’ comment]. 

QD Vision54 has characterized QD TV performance (luminance, colour, power 
consumption) for various TV settings. The luminance efficiency (nits/watt) vs. colour 
gamut is compared for various wide colour gamut TVs that are current in the market, 
and is shown in Figure  5-2 along with comparative data. QD Vision provides the following 
observations: 

  Hisense QDEF TV has better colour gamut and luminance efficiency compared 
to Samsung SUHD TV. Both these TVs have luminance greater than 500 nits. 

  Hisense Colour IQ TV (edge lit) has better colour gamut and luminance 

efficiency compared to Hisense QDEF TV (direct lit). Edge lit Hisense TV has 
400 nits luminance while the direct lit has 500 nits luminance. 

  Philips Colour IQ TV (edge lit) has the best luminance efficiency of all wide 
gamut TVs. All measured TVs have luminance greater than 400 nits. These 
results line up well with our expectations that for a given size (i.e. 55”) 1H 
orientation TVs lead the luminance efficiency, followed by 2V and finally by 
2H designs. 

  TCL and Thomson Colour IQ TV (edge lit) has the best colour gamut of all wide 

gamut TVs. 

  Samsung Direct lit UN55JS7000F (direct lit) does not use QD film. It uses a LED 
with RG phosphor and a notch filter film to minimize Green-Red channel leak 
to improve colour quality. 

53 Op. cit. QD Vision (2015a) 
54 QD Vision (2015b), Benchmarking of QD Televisions, submitted 28.10.2015, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_QD_Exs__QD_Vision_e_QD_
Television_Benchmarking.pdf  

34 

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Figure ‎5-2: QD Vision Comparison of Luminance Efficiency (nits/watt) vs. 
Colour Gamut for Various Wide Colour Gamut TVs on the Market 

Source: QD Vision (2015b) 

3M DMSD55 notes that devices containing displays (such as televisions, monitors, 
notebooks, tablets, phones, etc.) are designed and implemented by different 
manufacturers to meet a variety of different needs. While it is possible to measure the 
colour, luminance, and power consumption of multiple devices, comparing these data is 
not a meaningful way to compare the relative performance of specific components 
within the devices. Too many other attributes vary among different devices since a 

55 Op. cit. 3M DMSD (2015) 

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35 

 
 
 
                                                       
 
display is an entire system that combines components, and the combination of the 
performance characteristics impacts the overall system performance. For example it is 
possible that a device could have an extremely efficient colour enhancement film, but 
has overall low energy efficiency because of poor electronics design or the choice of 
cheaper and lower efficiency LEDs. In 3M’s experience, the only meaningful way to 
compare the relative performance of different, specific components is to evaluate those 
components in the same device so that the performance of the particular component is 
isolated, thus eliminating other factors introduced by testing differing systems. 3M 
DMSD has evaluated one sample each of two commercial InP-based TV models and 
modified them with 3M Cd-based film. At equivalent luminance, the two TVs with Cd-
based QDs consumed 15% and 29% less power than the TVs with InP-based QDs while 
still providing 12% and 13% higher colour (see Table  5-6). 3M DMSD uses this 
comparison to show that replacing the InP QD sheet with the CdSe QD sheet results in 
both an increase in luminance (28% and 39%) and colour gamut (13% and 12%) of Rec. 
2020 overlap. 3M DMSD further states that by decreasing the electrical current to the 
LEDs (and, hence, reducing energy consumption of the LEDs), the TVs with different QD 
chemistries can be made to have the same luminance. This is achieved in practice by 
reducing the backlight setting of the TV. The luminance and power as a function of 
backlight settings were characterized for both TVs and found to be linear with a 
coefficient of determination (R2) of >0.999. These relationships are used by 3M DMSD to 
determine the power consumptions at equivalent luminance, which are reported in 
Table  5-7. 
3M DMSD56 also states that it is impossible to infer the energy impact of two different 
display components by comparing the EU energy rating of two different TVs that use 
those components. The fact that one type of television that utilizes CdSe QDs consumes 
more power than a different type of television that utilizes InP QDs says nothing about 
the efficiency characteristics of different QDs. 

Table ‎5-6: 3M DMSD Measured Performance Comparison of TVs at Constant 
Power (Different Luminance and Colour) 

Source: 3M DMSD (2015) 

56 Op. cit. 3M DMSD (2016a) 

36 

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Table ‎5-7: 3M DSD Measured and Calculated Performance Comparison at 
Constant Luminance 

Source: 3M DMSD (2015) 

In contrast, Nanoco uses an approach of comparing different TVs to establish the 
differing capabilities of the various technologies. According to Nanoco57, manufacturers 
do not publicly provide the detail needed for a full comparison. However, Nanoco 
provides a comparison of energy efficiency using published data, shown in Table  5-8. 

Table ‎5-8: Nanoco Comparison of Energy Efficiency of Various Displays 

Source: 55“ comparison: Nanoco (2016b) and 65“ comparison: Nanoco (2016a) 

57 Op. cit. Nanoco (2016a) 

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On the basis of internal testing, Nanoco also provides a comparison of various displays in 
terms of colour performance, reproduced in Table  5-9. 

Table ‎5-9: Nanoco Comparison of Colour Performance of Various Displays 

Note: the Kindle tablet was not designed to have a very high colour gamut, but rather it was optimised for 
low power consumption to improve battery life so the colour gamut was deliberately restricted. 
Source: Nanoco (2015a) 

In order to compare the colour performance of cadmium and cadmium-free QD TVs, 
Nanoco58 obtained four commercially available samples of 55” 4K HD TVs, as shown in 
Table  5-10. The Samsung JS9000 was selected to represent cadmium-free and the 
Thomson UA9806 and Hisense XT910 to represent cadmium QD products available in EU, 
plus a TCL model that is available in China for a broader perspective. According to 
Nanoco, Thomson uses the ‘on-edge’ system with glass capillary and the other 3 all use 
‘on-surface’ QD film designs. The colour standard coverage was measured for each 
television using the CIE 1976 colour space. 

Table ‎5-10: Nanoco Comparison of Colour Performance of Various Displays  

Source: Nanoco (2016a) 

58 Nanoco (2016a), Page Response to Public Consultation Questionnaire Regarding Cadmium QD 
Exemptions, submitted 8.1.2016, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Quantum_Dot_Evaluation/N
anoco_Technologies_RoHS_response_final_20160108.pdf  

38 

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In a later communication, Nanoco59 provides additional comparisons, also referring to 
other alternative technologies and their performance. In Table  5-11 comparisons of 
displays are reproduced in relation to colour gamut, whereas Table  5-12 provides 
comparisons of energy consumption for television of 55” and of 65”. Nanoco explains for 
these comparisons that the Samsung KS9000 is a new 2nd generation model with 
increased efficiency that has recently been launched in the EU market and was not 
available at the time of the stakeholder consultation submission. 

Table ‎5-11: Nanoco Comparison of Colour Gamut Performance of Displays 

Notes: 1 CIE 1976 colour space; measured at Nanoco  
2 With colour filters selected for AdobeRGB performance  
3 Measured using a commercially available TV designed for DCI performance with cadmium-free QD film  
4 CIE 1931 colour space  
5 http://www.hdtvtest.co.uk/news/55eg960v-201504224046.htm   
6 http://www.pocket-lint.com/news/133728-lg-g4-ips-quantum-display-explained-how-is-it-different-to-a-normal-lcd   
7 
http://www.techradar.com/reviews/pc-mac/pc-mac-desktops/apple-imac-with-5k-retina-display-27-inch-late-2015-1310384/review  
 8 http://techon.nikkeibp.co.jp/english/NEWS_EN/20131217/323134/  
9 CIE 1976 colour space 
10 K. Yoshimura et al., White LEDs using Sharp β-sialon: Eu Phosphor and K2SiF6: Mn Phosphor for Wide-
Colour Gamut Display Application, IDW, 2015, ISSN-L 1883-2490/22/0504 
11 Y. Ito et al., SID Digest, 2013, 44, 816 
Source: Nanoco (2016b) 

59 Op. cit. Nanoco (2016b) 

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Table ‎5-12: Comparison of Energy Consumption of Displays 

Source: Nanoco (2016b) 

5.4.1 

Reliability of Quantum Dot Displays 

According to 3M DMSD, Cd-based QD film systems have been in the market since 
October, 2013. 3M DMSD performs extensive aging of its Cd-based QD films to meet 
customers‘ demands for device lifetimes in the 20,000 to 30,000 hour range. To date, 
3M has been unable to achieve acceptable reliability using the prototype sample InP QDs 
that have been provided by QD suppliers. 3M DMSD states that reliability data would 
need to be confirmed for fully scaled QD production. 60 

5.4.2 

Environmental Arguments 

Energy Savings and Cd Emissions 

5.4.2.1 
QD61 Vision provides calculations to show how energy savings related to a CdSe QD 
television shall result in subsequent savings of Cd emissions as well as other emissions 
(emissions CO2
combustion). As for the relation between the reduction in Cd emissions and the Cd used 
in respective displays, QD Vision states that the 25% improvement in energy efficiency 

 equivalents as well as of other heavy metals emitted from coal 

60 Op. cit. 3M DMSD (2015) 
61 Op. cit. QD Vision (2016c) 

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for CdSe-based QD implementations is based on a film-swap of InP film for CdSe film in 
both a Samsung and a Hisense QD-based television. This methodology was employed to 
isolate the relationship between the quantum dot material and luminance, which – in a 
test where all other variables are held constant – can be considered a proxy for energy 
performance. It is further explained that QD Vision uses an on-edge configuration 
because it is the lowest cost and, therefore, the most available QD solution, while using 
the minimum amount of Cd in a Cd-based solution; approximately 1.5mg for a 55” 
diagonal display. While QD Vision does not offer an on-surface QD configuration, it 
concurs with 3M’s submission, which estimates Cd levels of 3-5μg/cm2 typical, no more 
than 20μg/cm2 or approximately 16mg per 55” diagonal display. For reference, QD 
Vision states that InP-based QD displays of comparable size and performance require 
roughly 40mg of InP material. 
In respect to this last statement, the consultants note that 20μg/cm2 actually translates 
to 167mg of Cd for a 55” diagonal screen, this being 47.9” in width and 27” in height. The 
LCA submitted by QD Vision, in relation to which these statements have been made, 
estimates that “an on-surface film for the same size display [55“] would require 162 mg 
Cd“. QD Vision’s reference to 16 mg in this later communication is thus assumed to by 
typo, as also confirmed by the calculation. 

QD Vision argues that the use of CdSe-based QD technology enables significant savings in 
Cd emissions, when considering the Cd emissions related to energy production. In 
addition to the other advantages of wider colour and high energy savings, the total Cd 
savings are estimated as roughly 10 times the amount of Cd used in an on-edge display 
implementation, and somewhat greater but roughly equivalent to that used in an on-
surface implementation. This is said to be the “tip of the iceberg.” Seeing that power 
plant pollution control technologies have Cd-reduction efficiencies of between 90% for 
electrostatic precipitation and wet flue gas desulfurization, and 95% for fabric filters, QD 
Vision concur that for every 1.3mg of atmospheric Cd released, another 11.7 - 24.7mg of 
Cd would be captured from the stack and sent to European landfills. A reduction in 
consumed energy thus also saves these emissions – roughly 10 times the amount of Cd 
used in an on-edge display implementation and somewhat greater but roughly 
equivalent to that used in an on-surface implementation. 62 
3M DMSD submitted a report prepared by Goodman63 raising various socio-economic 
aspects. Among others it is stated that the use of a Cd QD TV will result in less cadmium 
in emissions and waste from electricity generation since these have been shown by 
comparative measurements to be more energy efficient than standard designs of LCDs 
and also InP QD LCDs used in a television. Calculations are provided to show what 
savings in energy and Cd emissions could be related to the use of a CdSe QD display in 
comparison to a standard display and in comparison to an InP one. Results of these 
calculations can be viewed in the report. 

62 Op. cit. QD Vision (2016c) 
63 Op. cit. Goodman (2015) 

Study to Assess RoHS Exemptions  

41 

 
 
                                                       
 
5.4.2.2 

Toxicity 

Various arguments are raised by the applicants and stakeholders as to the toxicity of the 
substances used to produce QD, in part opposing each other. 
QD Vision64 explains that CdSe is stable and the release of Cd(II) ions is very small in the 
absence of electron acceptors under reducing conditions. CdSe is subject to photo- and 
air oxidation and generates free radicals and therefore, gradual dissolution of CdSe can 
occur in the presence of electron acceptors such as oxygen. CdSe is insoluble in water. 
Dissolution of CdSe is pH-dependent, but the dissolution rate of CdSe is very low even 
under the most favourable acidic pH and/or aerobic conditions. 

According to QD Vision, there is not a significant amount of information on the toxicity 
and health effects of exposure to CdSe in the public literature. It is generally assumed 
that the systemic toxicity of Cd compounds is attributed to the Cd(II) ion. A few existing 
studies indicate that the oral bioavailability of CdSe is very low and its adverse health 
effects depend primarily on Cd(II) ions released from CdSe and free radicals generated 
from photo- and air oxidation of CdSe. A 28-day oral (sub-chronic) study in rats showed 
that CdSe did not cause any toxic effect at doses of 30, 300 and 1,000 mg/kg/day. No 
chronic studies are available on CdSe. The classification of CdSe is based on the 
categories of “cadmium compounds” and “selenium compounds”. Based on the CLP 
classification principles and considering the 28-day rat oral study, CdSe could be 
classified as Acute inhalation and dermal toxicity Category 4, Acute aquatic Category 1 
and Chronic aquatic Category 1. CdSe is classified as much less hazardous as the 
classification for cadmium itself.65 

As for InP, QD Vision states that InP is insoluble in water, soluble in simulated gastric 
fluid and hardly soluble in simulated lung fluids. InP was determined to be a 1B probable 
human carcinogen based on well-conducted inhalation toxicity studies in experimental 
animals. The evidence includes high incidences of malignant neoplasms of the lung, 
adrenal and liver in rats and mice exposed to InP as low as 0.03 mg/m3 and for as short 
as 22 weeks. InP was subject to a harmonized classification proposal sponsored by 
France and reviewed by the Risk Assessment Committee in 2009 in association with EU 
CLP regulation. The harmonized classification of InP is Carcinogen 1B (H350), 
Reproductive toxicant Cat 2 (H361f), and specific target organ toxicity (STOT) Repeat (RE) 
Cat 1 (H372).66 

QD Vision summarises that the risks of InP and CdSe should not be exaggerated – 
particularly in the QD form that they have they present no hazard to the user or the 
environment. Only at the point of recycling can there be an issue of exposure to workers 
however this is not materially different from far greater risks involved in recycling work. 
According to QD Vision, it is arguable that as a suspected carcinogen, the vastly higher 

64 Op. cit. QD Vision (2015) 
65 Op. cit. QD Vision (2015) 
66 Op. cit. QD Vision (2015) 

42 

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quantities of InP required and due to its lower recycling rate, InP is the slightly more 
harmful substance. What further argues in favour of CdSe is that by being on the market, 
further reduction steps are being taken and it is possible that the 0.01% concentration 
limit [the RoHS restriction threshold for Cd – consultants’ comment] will be met in the 
not too distant future. For these developments to happen the technology must remain 
on the market at this critical stage.67 
3M DMSD68 supports for the most part QD Vision’s point of view, however also states 
that that correctly predicting the hazards of either an InP-based or CdSe-based quantum 
dot in the absence of toxicological data is difficult. While it may seem preferable to 
replace a compound containing cadmium with an unidentified compound without 
known human health hazards, it is possible that there is no hazard reduction from 
replacing the cadmium containing compound, and that the replacement may be a 
regrettable substitution. Nonetheless, since there is no exposure to quantum dots in 3M 
QDEF during typical use phase, the film poses no health risk to consumers. 

In contrast, Nanoco regards the toxicity of their own QDs, explained to be based on In 
but not on InP, to be lower than that of Cd QDs. Nanoco69 claims for example that a 
further advantage of CFQD® materials is their very low toxicity, because they are 
cadmium-free and are not made from indium phosphide. Nanoco presents testing 
results carried out to regulatory standards that show how CFQD® quantum dots are 
much safer than cadmium selenide, the material used to make most cadmium-based 
QDs: 

67 Op. cit. QD Vision (2015) 
68 Op. cit. 3M DMSD (2016a) 
69 Op. cit. Nanoco (2016b) 

Study to Assess RoHS Exemptions  

43 

 
 
                                                       
 
Table ‎5-13: Nanoco’s‎Survey‎on‎Testing Results for CFQD® and CdSe 

Source: Nanoco (2016b) 

5.4.2.3  Resource Use and Recycling 
QD Vision70 explains that the raw material used for synthesis of QD precursors, cadmium 
oxide (CdO), can be produced from recycled Cd very easily. QD Vision currently 
purchases CdO from distributors who procure CdO from global suppliers, some of whom 
do not distinguish the source of their Cd. However, in the course of this exemption 
process, QD Vision has identified a recycling company who would be able to supply 100% 
recycled CdO with the ability to globally source waste Cd, including materials from 
Europe. QD Vision was, however, not able to provide an estimation as to how much of 
the CdO purchased for conversion to QD precursors has been derived from recycled Cd 
feedstocks. 

5.4.3 

Road Map to Substitution 

Various statements made suggest that once a Cd-free QD alternative becomes available 
on the open market, which provides comparable colour gamut performance and 
efficiency, that it would replace CdSe in QDs. However, a detailed roadmap is not 
provided. The applicants do not detail what research they are undertaking or promoting 
to enable this substitution, nor what the timeline and the stages towards a full 
substitution may be.  

70 Op. cit. QD Vision (2016c) 

44 

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5.5 

Stakeholder Contributions 

Aspects raised in this chapter are relevant for applications of QD technologies in both 
displays and solid state lighting. A similar chapter is thus not included in the chapter 
evaluating QD solid state lighting applications. 
The American Lighting Association (ALA)71 explains the trade-off made by developers of 
LED technologies between efficacy (lumens per watt) and light colour performance. This 
is explained to be motivated by the general strive to reduce energy consumption related 
to lighting.  Industry is expected to need to pay more attention in the future to customer 
needs in terms of colour performance, if more efficacious colour sources are to enter 
residential homes. ALA supports the requests, explaining that maintaining exemption 39 
shall “allow time for manufacturers to finalize designing these materials into their 
products, and to test the products to determine their advantages and disadvantages. 
Eliminating the exemption at this time would be detriment to the years of research and 
development aimed at improving energy efficiency as well as the consumer experience.” 
BASF72 explains that it has recently signed a joint development agreement with QD 
Vision for a QD enhanced backlight and a colour filter for use in LCDs. It supports the 
request and raises various advantages of this technology for displays, which are already 
mentioned for the most part in the sections above and thus not repeated here. 
Department for Business and Innovation Skills (BIS)73 objected to the applicants’ 
requests to exempt the use of cadmium in quantum dot technology in the past, as the 
effect of such measures meant that quantum dot technology containing cadmium and 
cadmium free  would be allowed on to the EU market until July 2018. Even at that time, 
cadmium free technology was being commercialised and was already available in certain 
markets since the start of February 2015. BIS urges the EC to speed up the current 
evaluation so that should the exemptions be denied, that this not extend the period 
under which such Cd-based technologies can be placed on the market beyond necessary. 
The International Chemical Secretariat (ChemSec)74 does not support the requests for 
exemption, explaining that Cd causes serious illness and presents severe danger to the 

71 ALA (2016), The American Lighting Association, Contribution to consultation on the Revaluation of Two 
Requests Related to Cd-QD Technologies, submitted 8.1.2016, available under 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Quantum_Dot_Evaluation/t
he_American_Lighting_Association_ALA_Cadmium_Letter.pdf  
72 BASF (2016), BASF, RoHS Exemption Request 2013-2 QD Vision, submitted 8.1.2016, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Quantum_Dot_Evaluation/B
ASF_QD_Vision_Oekoinstitut.pdf  
73 BIS (2016), Department for Business and Innovation Skills, Contribution to Stakeholder Consultation 
2015-3 – Joint Revaluation of Two Requests for Exemption, First Reviewed in 2013-2014, Related to 
Cadmium Quantum Dot Applications, submitted 7.1.2016, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Quantum_Dot_Evaluation/D
epartment_for_Business_Innovation_Skills_Contribution__Exemption_39_8_Jan_2016.pdf  
74 ChemSec (2015), the International Chemical Secretariat, Response to 2015 Consultation 3: Joint 
Revaluation of Two Requests for Exemption, First Reviewed in 2013-2014, Related to Cadmium Quantum 

Study to Assess RoHS Exemptions  

45 

 
 
                                                       
 
environment, throughout the production chain and should therefore be restricted. This 
they explain to be even more relevant in cases where alternative technologies are 
available, as an exemption would discourage sustainable and responsible innovation, 
having a great environmental impact, which can be avoided. It is further elaborated that 
though some stakeholders warn against the carcinogen properties of indium phosphide, 
one of the alternatives, that ChemSec, despite also having warned against the dangers of 
InP in the past, does not believe that this aspect should be construed as support for a 
CdQD technology.  
The Close Brothers Asset Management75, Baillie Gifford & Co76 and Henderson Global 
Investors Ltd77 explain that they do not find merit in the requests at hand. They do not 
support the requests given the availability of safer alternative materials.  
DOW Europe GmbH78 endorses the submission made by Nanoco on 8 January 2016 and 
emphasis various aspects in relation to the Nanoco submission, which are already 
mentioned for the most part in the sections above and thus not repeated here. 
The European Environmental Bureau79 states that it is a known fact that cadmium and 
other heavy metals may cause serious illnesses and present a severe danger to the 
environment, throughout the production chain. Cadmium and other heavy metals in 
consumer products should therefore be restricted. This is even more necessary in cases 

Dot Applications, submitted 21.12.2015, available under 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Quantum_Dot_Evaluation/1
51221_PC_RoHS_Cadmium_Chemsec_FINAL.pdf  
75 Close Brothers (2015), The Close Brothers Asset Management, Response to 2015 Consultation 3: Joint 
Revaluation of Two Requests for Exemption, First reviewed in 2013-2014, Related to Cadmium Quantum 
Dot Applications, submitted 21.12.2015, available under 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Quantum_Dot_Evaluation/2
1122015_OKO_INSTITUT_LETTER_FROM_RFM__2_.pdf  
76 Baillie Gifford (2015) Baillie Gifford & Co, Response to 2015 Consultation 3: Joint Revaluation of Two 
Requests for Exemption, First reviewed in 2013-2014, Related to Cadmium Quantum Dot Applications, 
submitted 22.12.2015, available under 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Quantum_Dot_Evaluation/L
etter_to_Ms_Baron_Related_to_Cadmium_Quantum_Dot_Applications_21_Dec_20....pdf  
77 Henderson (2015), Henderson Global Investors Ltd, Response to 2015 Consultation 3: Joint Revaluation 
of Two Requests for Exemption, First reviewed in 2013-2014, Related to Cadmium Quantum Dot 
Applications, submitted 16.12.2015, available under 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Quantum_Dot_Evaluation/H
wnderson_Globa_Investors201512231029.pdf  
78 Dow (2016), DOW Europe GmbH, Contribution to Stakeholder Consultation, submitted 8.1.2016, 
available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Quantum_Dot_Evaluation/D
OW_Europe_GmbH_Letter_RoHS_Jan_2016_final_.pdf  
79 EEB (2015), The European Environmental Bureau, Response to 2015 Consultation 3: Joint Revaluation of 
Two Requests for Exemption, First reviewed in 2013-2014, Related to Cadmium Quantum Dot 
Applications, submitted 7.12.2015, available under 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Quantum_Dot_Evaluation/2
0151207_EEB_response_to_RoHS_Exemptions_Evaluation.pdf  

46 

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where clean alternative technology is available. EEB fully supported the European 
Parliament’s vote to reject the Delegated Act by the EC extending the use of toxic 
cadmium in televisions and other displays until July 2018, as displays using Cd-free QDs 
had become widely available, whereas Cd-based displays had all been withdrawn from 
the EU market since 2014. 
Hinsense80 produces ultra-high definition (UHD) televisions, which contain 3M QD 
Enhancement Films that leverage Cd-based QDs to bring about more vivid colours. 
Hinsense supports the two requested exemptions, claiming that UHD televisions that 
utilize Cd-based QD technologies are demonstratively more efficient than QD 
technologies comprised of other materials, i.e. indium-based solutions. Hinsense 
believes that Cd-based QD technology remains the only viable way to simultaneously 
achieve high-colour performance and energy efficiency.  Discontinuing the exemption 
may lead to an increase of consumers’ electric bills, and may contribute to an overall 
negative impact on the environment. 
InGaN Research Ltd81objects the requested exemption is granted. InGaN raises various 
questions of importance for the evaluation at hand. In InGaN’s view, Quantum Dots are 
not a new technology and have been available for over a decade in many applications 
and industrial sectors. There are a significant number of questions that still need to be 
answered in regards to nanomaterials (both Cadmium and Cadmium free) suitability for 
the wider environment especially in terms of health impacts however it is clear that 
heavy-metal based Quantum Dots cannot be good for the environment and EU Citizens 
health in the long term. InGaN claims that the aims of the original RoHS and REACH 
directives were to limit and remove hazardous materials within Europe, with exemptions 
being a method of last resort to allow the market to transition itself responsibly to 
alternatives and environmentally symbiotic alternatives. The previous exemption for Cd-
based QDs has provided ample time for the Industry to make that transition and InGaN 
argues that the market for Cd-based QDs within the Display and Lighting Industry has 
failed due to technology performance and consumer concerns. The number of units 
shipped in the display and lighting markets that contain CdQDs is less than negligible and 
therefore an outright ban would not impact the general market through restricted 
supply chain or consumer choice and provides a strong commercial case to reject the 
proposed exemption extension.  

80 Hisense (2016) Hinsense, About Quantum Dot Enhancement Films, submitted 8.1.2016, availiable under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Quantum_Dot_Evaluation/H
isense_Contribution.pdf   
81 InGaN (2016), InGaN Research Ltd, Response to 2015 Consultation 3: Joint Revaluation of Two Requests 
for Exemption, First reviewed in 2013-2014, Related to Cadmium Quantum Dot Applications, submitted 
8.1.2016, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Quantum_Dot_Evaluation/I
nGaN_Research_Ltd_Response_to_RoHS_exemption_of_QDs_-_7-1-16.pdf  

Study to Assess RoHS Exemptions  

47 

 
 
                                                       
 
The Swedish Chemicals Agency (KEMI)82 regrets that a final decision is still lacking for 
the exemption requests for cadmium in quantum dots. Any further delay will prolong the 
possibility to place on the market equipment containing elements made with quantum 
dot technology that contains Cd. KEMI suggests that the applications for exemptions be 
refused and that exemption 39 be terminated as fast as possible according to the rules in 
the RoHS directive. Since the products were not introduced to the EU market at the time 
of the original application/reapplication for an exemption, the transition time for the 
current exemption 39 should be as short as possible (12 months). The intention must be 
to avoid the risk of an expanding market of cadmium containing products in the EU, for 
which the shortest possible transition period shall act as a clear signal that such products 
should not be introduced on the EU market. KEMI argues that alternatives are available, 
both using QD technologies and using other technologies. In this respect it is further 
explained that the Article 5(1)(a) criteria would not be fulfilled in respect of substitutes 
as KEMI does not interpret “general use in lighting or displays” as a specific application 
for which exemptions can be granted. Furthermore, it can be understood that should an 
exemption not be available, this would not result in a lack of supply of lighting and 
display applications on the EU market. There would still be televisions, monitors, tablets 
and cell-phones as well as light bulbs free from cadmium available for sale. If there is 
equipment for a specific application where the quantum dot technology with cadmium is 
necessary to set this type of equipment on the market, new applications should be 
submitted particularly for that equipment.  
KEMI83 disagrees with the way the functional parameters for comparing performance of 
Cd free and Cd-based technologies are defined by the applicants, because the question is 
based on incorrect premises. Exemptions shall be given for “specific applications”, not 
for a specific technology. A definition of the functional unit should start with a specific 
equipment from one of the categories in Annex I of the RoHS directive. Since there are 
cadmium free televisions, monitors, tablets and cell-phones as well as light bulbs 
available for sale, this specific technology is not crucial for the basic lighting function of 
those kind of equipment. Thus all claims regarding functions should be made in relation 
to a specific equipment. If necessary in various equipment, multiple exemption 
applications may be submitted for the function of such equipment. 
In relation to environmental impacts at EoL, KEMI84 states that one of the applicants 
state that “Furthermore, the cadmium in the QD-LCD can be recovered safely by 
recycling whereas the cadmium and other toxic metal emissions from power generation 

82 KEMI (2015), The Swedish Chemicals Agency, Contribution to Stakeholder Consultation 2015-3  -  Joint 
Revaluation of Two Requests for Exemption, First Reviewed in 2013-2014, Related to Cadmium Quantum 
Dot Applications submitted 21.12.2015, submitted 21.12.2015, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Quantum_Dot_Evaluation/S
E_CA_Answer_to_SC_RoHS_2015_3_Joint_Revaluation_of_cadmium_in_quantum_dots.pdf  
83 Op. cit. KEMI  (2015) 
84 Op. cit. KEMI  (2015) 

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contaminate the environment, enter the food chain, etc.”. KEMI comments that the 
safety of the recycling process seems to be highly overestimated by the applicant. The 
described safe recovery of Cd from displays and light sources in electronic waste 
requires that the workers of recycling facilities have knowledge about which of the parts 
contain cadmium. Since there are no such systems for transmission of information, it will 
not be possible to ensure that such safe recovery will occur. 
LightingEurope (LEU)85 supports the requests for exemptions, claiming that past 
argumentation remains valid and is currently also backed with recent external research 
backing the efficacy improvements of Cd QDs in comparison with other alternatives on 
the market. LEU raises various aspects, which are already mentioned for the most part in 
the sections above and thus not repeated here. 
Nanosys86 supports the requests at hand, providing test results of a further “swap” 
comparison of Cd-based and Cf-free QD films in displays. Results are not reproduced 
here as they are similar in nature to those presented of the applicants. Nanosys 
concludes that Cd-free (InP) quantum dots have progressed significantly in the past year 
from being the subject of academic papers and conjecture to being used in successful 
commercial products. However, they are not the dominant quantum dot technology in 
use today. Nanosys believes that Cd-free quantum dots will continue to make progress 
over the coming year, but would recommend based on their analysis and the review of 
the LCA report submitted by 3M, that 2013-5 be granted for at least one year. 
NDF Special Light Products BV87 is a manufacturer of CFLs and since 2010 it also 
produces LEDs in combination with remote phosphor. It objects to the requests, 
explaining that Cd is restricted because of the widely known health risks associated with 
it. While NDF Special Light Products B.V. has warned against the dangers of indium 
phosphide, it believes that this should not be construed as support for Cd QD 
technology. 

Other contributions made by 3M, CREE, Lumileds, Nanoco and QD Vision are not 
mentioned here as they have been included in the course of the report. 

85 LEU (2015) LightingEurope, Support Letter on Exemption 39, submitted 9.12.2015, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Quantum_Dot_Evaluation/L
E_support_letter_RoHS_Ex_39_Cadmium_20151209.pdf  
86 Nanosys (2016), Input for stakeholder consultation for RoHS exemption requests 2013-2 and 2013-5, 
submitted 8.1.2016, available under 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Quantum_Dot_Evaluation/N
anosys_Input_for_Stakeholder_Consultation_-_CdSe_vs_InP__Cd-
free__Quantum_Dot_Performance_Measurement_and_Analysis.pdf  
87 NDF (2015), NDF Special Light Products BV, NDF CW adj 1514 - Cadmium Quantum Dot applications, 
submitted 3.12.2015, available under 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Quantum_Dot_Evaluation/N
DF_CW_adj_1514_-_Cadmium_Quantum_Dot_applications.pdf  

Study to Assess RoHS Exemptions  

49 

 
 
                                                       
 
5.6 

Critical Review 

5.6.1 

REACH Compliance - Relation to the REACH Regulation 

Appendix  A.1.0 lists various entries listed in the REACH Regulation annexes that restrict 
the uses of various compounds. In the context of this exemption, the annexes were 
screened for entries related to cadmium, cadmium selenide, indium and indium 
phosphide, and the following was found: 

Entry 23 of Annex XVII restricts the use of Cd and its compounds in various applications. 
Paragraph 1 of this entry restricts the use of Cd in mixtures and articles produced from 
various synthetic organic polymers (thereafter referred to as plastic materials) and 
among others polyethylene terephthalate (PET). Mixtures and articles produced from 
these plastic material “shall not be placed on the market if the concentration of 
cadmium (expressed as Cd metal) is equal to or greater than 0,01 % by weight of the 
plastic material”. In the course of the 2013-2014 review, it was understood that QD films 
are manufactured using among other PET layers. However it was also clarified that the 
Cd QDs are immersed in a resin, located between two sheets of PET. In this sense Cd is 
not understood to be in the PET and this article would not apply. Other paragraphs 
restrict uses in paints, in metal plating, brazing fillers and jewellery. None of these 
applications are understood to be relevant to the exemption at hand. 

Various cadmium compounds are also restricted through entry 28 including: Cd chloride, 
Cd fluoride, Cd oxide, Cd sulphide, Cd sulphate, Cd (pyrophoric), entry 29 and entry 30 
including: Cd chloride, Cd fluoride, Cd sulphate. As these entries refer to specific 
compounds, none of which is CdSe, they are understood to be irrelevant. 

Entry 28 also lists indium phosphide, and does not allow supplying this compound to the 
general public as a substance, a mixture or a constituent thereof. As InP used in QDs in 
displays and solid state lighting (SSL) is placed on the market as part of an article, this 
entry is understood not to be relevant. InP is not made available to the general public as 
a substance, a mixture or a constituent thereof. 

No other entries, relevant for the use of cadmium and its compounds or indium 
phosphide, related to the requested exemptions, could be identified in Annex XIV and 
Annex XVII (status April 2016). 

Based on the current status of Annexes XIV and XVII of the REACH Regulation, the 
requested exemption would not weaken the environmental and health protection 
afforded by the REACH Regulation. An exemption could therefore be granted if other 
criteria of Art. 5(1)(a) apply. 

5.6.2 

Introductory Note 

In the first review of these exemption requests, the market availability of actual products 
on the market made a comparison of the applications for which the exemption is 
requested and their potential alternatives complicated. Thus a first aspect in this review, 
also addressed in the communication of the EU Parliament, was to understand the 
availability of Cd QD displays as well as the availability of their alternatives. As pointed 

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out by the various applicants and stakeholders, the market status of QD displays has 
changed in the meantime, and though the market still appears to be rather dynamic, a 
range of products is available using CdSe quantum dots or using InP quantum dots.  

  From the information provided by 3M DMSD, QD Vision and Nanoco, it is 

observed that displays are available using CdSe QDs for the following sizes: 
55” (television), 27” and 15.6” (monitors, notebooks). A 7” display (E-book 
reader) was also available in the past; however its production was 
discontinued.  

  As for displays using InP, at present only televisions are understood to be 
available, however in a large range of sizes, ranging from 48” to 88”.  

In this sense, it seems that the current market situation can facilitate a better 
comparison and thus a better understanding as to the comparability of these two 
technologies. 

In parallel, non-QD technologies have been named, for which displays are on the market, 
which can be understood to also be potential alternatives to QD displays.  

The following section thus discusses the available information in relation to the following 
aspects: 

  Possible reasons for the differing market availability of QD products in the EU 

and beyond; 

  Comparability of CdSe QD displays and of InP QD Displays; 
  Comparability of CdSe QD displays and displays using other than QD 

technologies; and 

  Aspects related to the RoHS 5(1)(a) third criterion, i.e. impacts on the 

environment, on health and on consumer safety. 

5.6.3 

Scientific and Technical Practicability of Substitution 

Before reviewing the performance of the various displays, it is worth mentioning that the 
submitted information suggests a wider range of products being available beyond the 
EU. From the product lists submitted by QD Vision, it is understood that on the global 
market the following display sizes are available using CdSe QDs: 40-120” (televisions). 
For smaller displays (monitors, tablets) further sizes are not specified beyond the ones 
stated above.  

QD Vision suggests that the difference in the availability of various display sizes could be 
related to the uncertainty of the further availability of Ex. 39. Further supporting this 
assumption, QD Vision explains that the design of the various displays is not expected to 
limit their marketability to certain countries or regions.  

The consultants agree that there seems to be no apparent reason aside from the 
uncertainty of the exemption for the differing market strategies. However, this 
reasoning is in itself not logical, as the exemption is an existing one, for which a renewal 
was requested. Article 5(5) of the RoHS Directive stipulates in this respect “The existing 
exemption shall remain valid until a decision on the renewal application is taken by the 

Study to Assess RoHS Exemptions  

51 

 
 
Commission”. Article 5(6) further clarifies that “In the event that the application for 
renewal of an exemption is rejected or that an exemption is revoked, the exemption shall 
expire at the earliest 12 months, and at the latest 18 months, after the date of the 
decision”. In this sense, even were the exemption to expire tomorrow, it would still 
remain valid for at least 12 more months. It is observed that the period throughout 
which display articles are sold on the market in some cases is quite short (many displays 
placed on the market in the past are understood to no longer be made available, for 
example many of the Sony TVs, the Kindle device, etc.). 3M’s statement that the market 
lifecycle of an electronic device is 6-12 months supports this understanding. Thus, 
though the uncertainty of the exemption duration could explain other display 
manufacturers not developing QD displays, it does not support that ones who have 
would not place certain articles on the EU market for fear of the fate of the exemption. 
The consultants would like to note the importance of this aspect to the case of a short 
termed exemption. Regardless of how manufacturers shall choose to develop displays in 
the future, it cannot be claimed that a short termed exemption would put EU consumers 
at a disadvantage to non-EU consumers in relation to display choice. As long as an 
exemption is valid and assuming that its renewal would be timely requested when 
necessary, manufacturers can expect that should the exemption be revoked, a transition 
period would be provided to facilitate the legal withdrawal of affected products.  

As it can be understood that there is already a wider availability of products, the next 
aspect to be reviewed concerns their performance. The applicants and other 
stakeholders have stated that CdSe QD can provide advantages in terms of their higher 
colour gamut and in terms of their (lower) energy consumption and (higher) efficiency. 
To support this claim, QD Vision, 3M and others provide “Swap” comparisons, in which 
televisions using QD films of one type have been swapped with the other type in order 
to compare performance of the QD film within the same display. This approach is 
explained to allow establishing that the performance of CdSe QDs is superior to that of 
InP ones, once all other parameters are held constant. Data presented from such 
comparisons indeed shows that CdSe QDs can provide better performance in relation to 
both colour gamut and energy consumption.  

 

  QD Vision’s data, using two 55” televisions for the “swap” comparison, shows 
a 9.6-10% difference in the coverage of NTSC, in the favour of CdSe, which 
also provides a 32% increase of luminance. This increase, when compared to 
the power is understood to result in an efficiency difference of 23-25%, 
depending on the display tested.  
In results of a swap comparison presented by 3M in which a 48” and a 65” 
television were compared, the range of difference was wider, with the energy 
consumption of CdSe TVs being 15 % to 29% lower. In parallel, this 
comparison shows that there is a 12-13% colour difference in relation to the 
Rec 2020 standard, however the higher coverage achieved by the CdSe TVs is 
still only 75%. In contrast, the DCI P3 difference is of only 0.7-1.6% and the 
NTSC Coverage difference is 10.4-11.5%.  

52 

17/05/2016 

 
 
For convenience, the data are summarised in Table  5-14. Results of the Nanosys88 
“swap” comparison are also presented to allow a wider basis of data for conclusions. The 
Nanosys comparison was done using the Vizio television model P65, which is a direct 
backlit, 65” UHD television that does not use QD dots. The original white LEDs were 
replaced with blue LEDs and a QD film was added (CdSe or InP based) The comparison 
also provides data for the original configuration of this display, which has not been 
reproduced here. 

Table ‎5-14: Results of Applicant's "Swap" Comparisons 

Television  

Film used 

Luminance 
efficiency 
(lm/w) 

NTSC 
Area 
(1931) 

DCI-P3 
Overlap 

Rec 2020 
Overlap 

Source 

Samsung 
48” 
Difference 

Hinsense 
55” 
Difference 
Samsung 
55” 
Difference 

With 3M film (CdSe 
As received (InP) 
Favouring CdSe 

Hinsense QDEF (CdSe) 
Samsung QD film (InP) 
Favouring CdSe 
Hinsense QDEF (CdSe) 
Samsung QD film (InP) 
Favouring CdSe 

Samsung 
65” 

With 3M film (CdSe 
As received (InP) 

Difference 

Favouring CdSe 

2.77 
2.17 
21.8% 

2.74 
2.12 
22.7% 
3.25 
2.45 
24.3% 

1.75 
1.25 

28.3% 

99.9% 
88.4% 
11.5% 

97.1% 
87.9% 
9.2% 
101.3% 
91.7% 
9.6% 

99.7% 
89.3% 

10.4% 

Visio 65”, 
blue LEDs 
Difference 

With 3M film (CdSe 
Samsung QD film (InP) 
Favouring CdSe 

3.95E+18* 
5.225E+18* 
24% 

n.a 
n.a 
n.a 

91.6% 
90.0% 
1.6% 

74.6% 
65.9% 
8.7% 

n.a 
n.a 
n.a 
n.a 
n.a 
n.a 

91.1% 
90.4% 

0.7% 

94% 
92.7% 
1.3% 

n.a 
n.a 
n.a 
n.a 
n.a 
n.a 

74.5% 
66.6% 

7.9% 

85.4% 
73.7% 
11.7% 

3M DMSD 
(2015) 

QD Vision 
(2015b) 

QD Vision 
(2015b) 

3M DMSD 
(2015) 

Nanosys 
(2016) 

Differences between CdSe and InP performance are calculated by the consultants. n.a=data not available. 

Numerical values rounded to two decimal places by the consultants  

Nanosys (2016) also provided results of a “swap” comparison, which are only summarised in this table and 
not detailed elsewhere in this report.   

*Nanosys did not provide data as to luminous efficiency, but calculated the photon conversion ratio, i.e., 
the ratio between the photons being produced by television set and between its photon input (the same for 
both sets). 
Source: Compilation of applicant and stakeholder data.  

From these results it can be understood that CdSe QDs may have advantages in terms of 
energy consumption and colour gamut, however the range of advantage depends on the 
products in which they are used, i.e., the technology of the display. In terms of colour 
gamut, it can be observed that the advantage depends on the standard used for 

88 Op. cit. Nanosys (2016) 

Study to Assess RoHS Exemptions  

53 

 
 
                                                       
 
comparison, however it is possible as mentioned by Nanoco89, that displays are designed 
to optimise performance against one of these standards and not against all. In this case 
the question would be whether the performance difference is significant for the 
standard for which the display had been optimised. In the comparisons of QD Vision, 3M 
DMSD and Nanosys, the Cd QD displays all show better colour gamut, though in some 
cases the difference may be less significant. Based on the comparison of standards 
provided by 3M and reproduced in Table  5-5, the consultants understand the results to 
be inconclusive. NTSC is said to cover about 38% of the colours visible to the human eye, 
DCI P3 to cover 42% and Rec 2020 nearly 100%. Though differences in the colour gamut 
performance are more significant when compared to NTSC (9.2-11.5 %) and Rec 2020 
(7.9-11.7 %), they are much less significant when compared to DCI P3 (0.7-1.6%). The 
data from the three comparisons also does not allow showing a trend related to the size 
of the display in this respect. Nevertheless, all comparisons show a significant advantage 
for Cd QDs in terms of luminous efficiency. Though this difference varies, in all cases the 
displays using CdSe Qds exhibit a higher efficiency by at least 20% to the InP 
counterparts. Though the QD Vision and 3M DMSD data could suggest a relation 
between the luminance efficiency benefits and the size of the display, the Nanosys data 
does not support this trend. 

A second approach for display comparison is of actual products available on the market. 
Some of these comparisons are based on internal measurements and some on producer 
declarations. Results of such comparisons are interesting for two reasons. They show 
that the preference of QD technologies do not translate directly to a preference in the 
television set performance (colour, energy consumption). More importantly, they allow 
a partial comparison between QD technologies and other technologies (in relation to 
colour gamut and in some cases to luminance efficiency). 

QD Vision compares 10 displays of which 9 are of the 55” size, 7 using CdSe QDs, one 
using InP QDs and one not being a QD Display (see summary in Table  5-15 as well as 
Figure  5-2 for graphic comparison). 

Table ‎5-15: QD Vision Comparison of Luminance Efficiency (nits/watt) vs. 
Colour Gamut for Various Wide Colour Gamut TVs on the Market 

Source: QD Vision (2015b) 

89 Op. cit. Nanoco (2015a) 

54 

17/05/2016 

 
 
                                                       
 
This comparison clarifies that indeed the CdSe displays have better gamut colour in all 
cases, however when the detailed data is compared, the difference is understood not 
always to be significant. The Samsung InP TV has an NTSC area of 91.7% whereas the 
other displays range between 97% to 108.4%. Though a 16.7% difference at the top end 
of this range may be considered relatively significant, a 5.3% difference at the bottom 
end of the range is much less significant and hence all the more questionable against 
potential toxicological considerations etc. In this respect it is also important to note, as 
also observed in the 3M DMSD and Nanosys “swap” comparisons, that a preference in 
relation to one standard does not ensure a preference in relation to other standards. The 
NTSC preference observed from the table above cannot be concluded to suggest a 
preference in relation to additional standards. All the more so, as according to the 
standard comparison provided by 3M in Table  5-5, the NTSC standard covers less colours 
than for example the DCI-P3 and the Rec 2020 standards (38% in comparison to 42% and 
near to 100% of colours visible to the human eye, respectively). As for the energy 
efficiency, here the Samsung InP TV shows better performance than some of the CdSe 
models having an efficiency of 2.45 within the general range of 1.68-3.38. 

Nanoco has also made comparisons of current products and shows that InP televisions 
have better performance in terms of energy consumption, for example an annual energy 
consumption of 118-153 kWh as compared to 160-215 kWh for CdSe TVs (see Table  5-8). 
When comparing colour performance in relation to DCI P3 (see Table  5-9), it is observed 
that InP TVs have a coverage of 97, whereas CdSe show a coverage of 78 to 95. However 
Nanoco itself notes that the kindle tablet was not designed to have high colour gamut 
and both of these models are understood to be older, as Nanoco states they were 
withdrawn in 2014 as can be seen in Table  5-3). A comparison of colour gamut for 
additional displays, summarised in Table  5-16, shows that the performance depends very 
much on the standard chosen as well as on the technology.  

Table ‎5-16: Summary of Nanoco Comparative Data for Colour Gamut 
Performance of Displays 

Technology 

Rec 709/sRGB 

DCI-P3 

Adobe RGB 

NTSC 1953 

Rec 2020 

InP QDs (TVs) 

CdSe QDs (TVs) 

OLED (TVs) 

IPS Quantum 
(smartphone) 

Apple iMac Hi-
performance 
phosphors 
(monitor) 

Trigain* 

ß-sialon:Eu + 
K2SiF6:Mn4+ 
Phosphor* 

100% 

96-98% 

96% 

92% 

87% 

73% 

91-98% 

96-98% 

92-94% 

71-82% 

86% 

98% 

99% 

90% 

107% 

Study to Assess RoHS Exemptions  

55 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
*The consultants are not aware if actual products using these technologies are available on the market. 
Source: Compiled by the consultants 

This information suggests that though CdSe QDs can be used to provide higher colour 
gamut and/or lower energy consumption, that this is not always the case in products 
currently available on the market. Though the various comparisons show that in many 
cases the colour gamut performance afforded with the use of CdSe QDs can be 
significant (though not in all cases), in relation with energy consumption, this seems to 
depend very much on how the technologies are implemented aside from the QDs. It is 
further assumed that the time when the product first came on the market also 
influences the results. As can be expected, newer products, of all categories show better 
performance in comparison with their predecessors. For most models, however it is not 
clear when the display first came on the market and thus a trend cannot be assumed 
based on the various data.  

Nonetheless, from the “swap” comparisons, the consultants can follow that where all 
parameters determining the performance of a display are held constant except the type 
of QD film used, that CdSe provides higher performance than InP in relation to energy 
efficiency and colour gamut. This is understood to confirm that at least in the 
comparison with InP QD technologies, that CdSe QD technologies can provide a better 
performance, when all other factors are held constant. Though this conclusion is 
relevant for the comparison of CdSe QD displays and InP QD displays, it does not allow 
drawing conclusions as to other emerging technologies. In some cases these may show 
comparable colour gamut in relation to one standard, however it cannot be concluded 
on the basis of available data whether performance would be comparable for other 
standards, nor in relation to luminous efficiency. 

As for the ability to comply with the recently launched Rec 2020 standard, though all 
data suggest that InP QDs are still lagging behind CdSe QDs, neither of these 
technologies have achieved as of yet a full coverage of the standard, nor consistent 
coverage in all displays on the market. Though the consultants can agree that QDs may 
be a stepping stone in the direction of achieving Rec 2020 colour gamut, it is still not 
clear if either of these technologies could be the first to achieve full coverage. As QD 
Vision points out, this is also currently not observed as a justification for either of the 
technologies, as the standard was only approved at the end of 2015 and can be expected 
to promote innovation and further development in the display sector. 

In terms of reliability, both technologies are already available in products on the market. 
Under the assumption that products of unacceptable reliability would not reach the 
market, the reliability needs to be understood to be sufficient in both cases. In this 
respect it also needs to be mentioned that the market is very dynamic and that it is not 
clear if the quick withdrawal of products is a result of poor reliability or solely of rather 
short design cycles and general decisions on product strategies. This is also seen in 
relation to the differences in performance between products placed on the market for 
example in 2014 and those placed on the market more recently and is relevant for all 
displays and not just QD displays. 

56 

17/05/2016 

 
 
3M argues that InP QDs are not available on the open market and that this would 
hamper substitution. Though aspects of availability can be considered when deciding on 
the duration of an exemption, they are not understood to be a justification on their own. 
Furthermore, aspects of availability are understood to be of relevance when a product is 
at risk of being expelled from the market for which alternatives cannot be produced in a 
large enough market volume in order to cover the demand. However the case of QD 
technology is different than substitution related to other exemptions. In the case of 
most existing exemptions, the substitution of a product widely available is usually 
considered in comparison with a product, which is new on the market and possibly 
produced at much lower volumes. QD technologies, of both kinds, used in displays are 
still relatively new on the market. As such, their market share is still expected to be 
relatively small. Should QD Displays have a lower availability, this would only delay their 
general market uptake, and affect competitiveness of different manufactures, but 
cannot be assumed to create significant impacts on consumers. Such aspects are not 
understood to be relevant for justifying an exemption. 

5.6.4 

Environmental Arguments 

5.6.4.1 

Energy Consumption and Reduction of Emissions 

The applicants provide calculations to quantify the possible reduction of CO2e emissions, 
Cd emissions and emissions of other heavy metals. Though there is no argument that a 
reduction of energy can have a positive impact in terms of various environmental 
impacts, the calculations provided cannot be used to support that CdSe QD displays shall 
always achieve such benefits in comparison to other displays.  

Such advantages have been shown to exist by the applicants, when a CdQD film is used 
in a display to replace an InP film, in relation to the difference in energy consumption of 
the two displays.  
In an LCA prepared on behalf of QD Vision, Engler et al.90 explain that depending on the 
baseline selected, CdSe QDs improve energy efficiency by approximately 20-30 percent 
when compared to In-based QD TVs. Using the mid-point 25 percent improvement and 
emission rates calculated in the RPA analysis allow a calculation of the benefits related 
to the energy savings, as shown in Table  5-17. 

90 Op. cit. Engler et al. (2015) 

Study to Assess RoHS Exemptions  

57 

 
 
                                                       
 
Table ‎5-17: Lifetime Emissions Reductions for CdSe QD TVs Compared to 
In QD TVs 

Notes: Assumptions: 25% improvement in energy efficiency (CdSe QD TV vs In QD TV), 30,000 hour (20.5 yr) 
lifetime for each TV, and 35% market penetration (20 million TVs in EU). Emission rates from RPA91 
document. 
Source: Engler et al. (2015) 

However, this estimation is based on a lifetime of 30,000 hrs or 20 years, assuming the 
television is operated for 4 hours per day. According to Prakash et al.92, 50% of the 
televisions disposed of in Germany do not reach the age of 10 years. Though it cannot be 
concluded that this is true throughout the EU, in the consultants view, a 20 year service 
life at 4 hours per day is an over-estimation, meaning that the estimated emission 
reductions could be lower. In this respect it should be noted that displays using an on-
surface configuration shall have a higher content of Cd (between 25-167 mg for a 55” 
television on the basis of 3-20 µg Cd per cm2). It is possible that the energy savings of an 
on-edge configuration television are comparable to that of an on-surface configuration. 

91 Referred to in Engler et al. (2015) as Risk & Policy Analysts (2015): Cadmium Selenide Quantum Dots—
RoHS Exemption Supporting Arguments. Final Report. 
92 Prakash el al. (2016), Prakash, S.; Antony, F.; Dehoust, G.; Gsell, M.; Köhler, A. R.; Schleicher, T.; in 
collaboration with Stamminger, R.; Oeko-Institut e.V. in cooperation with Friedrich-Wilhelm-Universität 
Bonn, Einfluss der Nutzungsdauer von Produkten auf ihre Umweltwirkung: Schaffung einer 
Informationsgrundlage und Entwicklung von Strategien gegen „Obsoleszenz" [Influence of the service life 
of products in terms of their environmental impact: Establishing an information base and developing 
policies against "obsolescence"] Commissioned by: German Federal Environment Agency (UBA), Dessau 
(FKZ UFOPLAN 3713 32 315), pg. 149, available under: 
https://www.umweltbundesamt.de/sites/default/files/medien/378/publikationen/texte_11_2016_einflus
s_der_nutzungsdauer_von_produkten_obsoleszenz.pdf 

58 

17/05/2016 

 
 
 
                                                       
 
However, this has not been substantiated, whereas the energy savings used for the 
above calculation are related to results of a swap comparison of CdSe and InP films in 
on-surface configurated televisions. In this sense, the Cd emission reductions throughout 
the life time of a television are expected to be below the assumed 1.5 mg of Cd 
contained in an on-edge Cd QD television and much lower than the amount of Cd used in 
the CdSe QD film of a television with an on-surface configuration. As for other reduced 
emissions, these are also expected to be lower than estimated. Thus the above results 
may give some indication, but should be treated cautiously. When weighing the possible 
use of Cd with the potential for reductions in emissions of other RoHS restricted 
substances, it should however also be kept in mind that Cd is not expected to emit from 
the QDs under normal operation. 

In contrast, it is also apparent that there are displays on the market using other than Cd 
QD technologies that consume less energy than some Cd QD ones. As is apparent from 
the various comparisons, there is a difference in the potential of CdSe QDs and in what 
they achieve in actual products on the market. In other words, the available information 
only supports that though advantages could be expected in some cases they should not 
be expected in all cases. There are still other displays consuming lower amounts of 
energy and in this sense it cannot be assumed that a wide range application of CdSe QD 
displays would result in significant energy savings and savings of related emissions in the 
EU.  

5.6.4.2 

Toxicity 

As for toxicity, the consultants agree that it is very difficult to compare between the 
toxicity of two substances without comprehensive data. The information provided by the 
applicants and by Nanoco shows various discrepancies, the source of which is not clear, 
aside from the understanding that the applicants compare between Cd and CdSe and 
between InP, whereas Nanoco compares CdSe to the compounds used in its own QD 
material, explained to be based on In but not on InP. 

The consultants have consulted the website of the European Chemicals Agency (ECHA) 
for information as to the classifications of the various substances. From the Registration 
database93 it is understood that neither CdSe nor InP are registered. The information 
retrieved is shown in Table  5-18. 

Table ‎5-18: Information from ECHA Registration Database  

Compound 

Cadmium Selenide 

Statements related to classification 
Classification 

Hazard Class and 

Hazard Class and 

Comments and source 

“Self”-Classification of a substance 
supplier. See: 

93 See http://echa.europa.eu/information-on-chemicals/registered-
substances?p_p_id=dissregisteredsubstances_WAR_dissregsubsportlet&p_p_lifecycle=1&p_p_state=norm
al&p_p_mode=view&p_p_col_id=column-
1&p_p_col_pos=1&p_p_col_count=2&_dissregisteredsubstances_WAR_dissregsubsportlet_javax.portlet.a
ction=dissRegisteredSubstancesAction 

Study to Assess RoHS Exemptions  

59 

 
 
                                                       
 
Compound 

Statements related to classification 

Category Code(s) 
Acute Tox. 3 * 
Acute Tox. 3 *  
Acute Tox. 4 * 
Carc. 1B 
Causes damage to 
organs through 
prolonged or 
repeated exposure 
Aquatic Chronic 1 

Category Code(s) 
H301  
H331 
H312 
H350 
H373 

H410 

Classification 

Hazard Class and 
Category Code(s) 
Carc. 1B 
Repr. 2 
STOT RE 1 

Hazard Class and 
Category Code(s) 
H350 
H361f 
H372 (lungs) 

Indium Phosphide 

Cadmium 

Classification 

Hazard Class and 
Category Code(s) 

Hazard Class and 
Category Code(s) 

Cadmium 

Acute Tox. 4 * 
Acute Tox. 4 * 
Acute Tox. 4 * 
Aquatic Acute 1 
Aquatic Chronic 1 

H332 
H312 
H302 
H400 
H410 

Selenium  

Classification 

Hazard Class and 
Category Code(s) 

Hazard Statement 
Code(s) 

Acute Tox. 3 * 
Acute Tox. 3 * 
STOT RE 2 
Aquatic Acute 1 
Aquatic Chronic 1 

H331 
H301 
H373 ** 
H400 
H410 

Comments and source 
http://www.sigmaaldrich.com/catalo
g/product/ALDRICH/244600?lang=en
&region=US  

Annex VI of CLP Regulation, Table 
3.1., updated 9 March 2016: 
http://echa.europa.eu/documents/1
0162/13626/annex_vi_clp_table_en.
xlsx 

http://echa.europa.eu/information-
on-chemicals/cl-inventory-
database/-/discli/details/51061  

Comment: cadmium compounds, 
with the exception of cadmium 
sulphoselenide (xCdS.yCdSe), 
reaction mass of cadmium sulphide 
with zinc sulphide (xCdS.yZnS), 
reaction mass of cadmium sulphide 
with mercury sulphide (xCdS.yHgS), 
and those specified elsewhere in this 
Annex:  
Source: Annex VI of CLP Regulation, 
Table 3.1., updated 9 March 2016: 
http://echa.europa.eu/documents/1
0162/13626/annex_vi_clp_table_en.
xlsx  
Comment: Classification for selenium 
compounds with the exception of 
cadmium sulphoselenide and those 
specified elsewhere in this Annex 
Source: Annex VI of CLP Regulation, 
Table 3.1., updated 9 March 2016: 
http://echa.europa.eu/documents/1
0162/13626/annex_vi_clp_table_en.
xlsx  

60 

17/05/2016 

 
 
 
 
 
 
In general it is noted that cadmium selenide currently does not have a harmonised 
classification and it is assumed that classification used by suppliers for marking and 
producing data sheets are thus based on separate classification statements of the 
substances cadmium and selenide.  

The availability of information as to the toxicity of CdSe and InP does not allow a 
conclusive comparison of their toxicity nor deriving a conclusion as to which would be of 
higher concern in the application at hand.  

5.6.4.3  Resource Use and Recycling 

In relation to indium it is argued among others that the use of this substance should be a 
concern in relation to insufficient recycling methods at end of life. This is also raised 
against its being identified as a critical material in terms of its availability as a resource. 
In this respect it should, however, be kept in mind that indium is used in displays in other 
components, and thus developing suitable technologies for its recycling is of concern, 
regardless of the possible use of In-based Qds. In an Oeko-Institute report of 2012 
concerning the recycling of critical raw materials from waste electronic equipment, 
Buchert et al. (2012) 94 state the following:  

“Indium is used in the form of indium tin oxide (ITO) as electrode material in flat 
screens. The advantage of indium tin oxide is that it is transparent, conductive 
and largely heat-resistant. The ITO layers applied in screens consist of 90% In2O3 
and 10% SnO2, corresponding to a percent by weight of indium of 78% (Böni & 
Widmer 2011). Whilst two layers of ITO are applied to LCD displays, OLED displays 
only have one layer. The literature gives different and often very contradictory 
data on the film thickness and indium content of flat screens… In LCD displays 
with LED background illumination, indium is also used as a component of the LED 
semiconductor chip which is largely composed of indium gallium nitride.”  

Buchert et al. estimate the quantity of In per display in relation to display size, 
reproduced in Table  5-19. 

Table ‎5-19: Mean Indium Content of Different Display Devices 

Source: Buchert et al. (2012) 

94 Buchert et al. (2012), Buchert, M.; Bleher, D.; Manhart, A.; Pingel, D.; Oeko-Institute, Recycling critical 
raw materials from waste electronic equipment [Recycling kritischer Rohstoffe aus Elektronikaltgeräten]   
Commissioned by: North Rhine-Westphalian State Agency for Nature Conservation, Environmental Affairs 
and Consumer Protection (LANUV), Recklinghausen, available under: 
http://www.oeko.de/oekodoc/1375/2012-010-en.pdf  

Study to Assess RoHS Exemptions  

61 

 
 
 
                                                       
 
A further aspect to be understood in relation to environmental and health impacts is 
related to the achieved colour performance of specific display applications. It is observed 
that currently CdQds seem to be closest to achieving the high colour gamut addressed in 
Rec. 2020 whereas in some areas of application, it can be followed that the colour 
performance can be critical to achieve certain environmental or health benefits. Such 
would be the case in the design of displays to be used for medical diagnostics or for 
monitoring and control of environmental impacts. In such cases the high colour gamut 
can thus be understood to possibly create subsequent benefits for the environment or 
for health. 

5.6.5 

Stakeholder Contributions 

Various aspects are raised by stakeholders both in support and in objection to the 
requests at hand. Some of these aspects are similar in nature to those detailed in the 
various sections of this report and thus are not referred to here again. 

A number of the stakeholders mention the purpose of the RoHS Directive in supporting a 
transition of the market away from the substances restricted therein. This can be 
understood to support the revoke of exemption 39 and to restrict further placing on the 
market of displays and lighting containing Cd QDs. In some cases such statements are 
made in relation to the availability of Cd-free alternatives providing similar functions, 
and in others these statements are made along with explanations as to the scope of 
exemptions that should be defined more precisely. These statements raise various viable 
aspects, for example in relation to the purpose of the RoHS Directive or as to the 
expected low significance of possible socio-economic impacts to incur should the 
exemptions be denied. However, the consultants understand the three primary criteria 
specified in Article 5(1)(a) to constitute the core mandate of this evaluation. Where the 
available information allows understanding that there are technical advantages to a 
certain technology, the consultants understand this to be the base for conclusions of this 
evaluation. Where other aspects are of concern, such as of social nature, these can be 
taken into consideration in the duration of a possible exemption. However further 
consideration of such aspects, beyond that which has been undertaken is understood to 
be beyond the mandate of the consultants. 

From the various contributions, it becomes apparent that a core question in the 
background of this evaluation is related to how an alternative and the baseline are 
respectively defined. When considering both display and lighting products, it is clear that 
alternative displays and alternative lighting applications both based on other 
technologies are available. Displays with lower colour gamut are available and are 
purchased by consumers, as are light sources with CRI below 90. The understanding that 
a wide range of display types are still purchased, shows that consumers have different 
preferences in relation to this product, not all attributing highest priority to colour 
gamut performance. The fact that such products are purchased, shows that consumers 
are willing to accept the lack of certain functions or properties. Though consumers may 
be willing to purchase products with additional properties, they cannot weigh the 
benefit from such functions against the technology or the substances it contains to 
provide such functions.  

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It may thus be worthwhile to consider whether the use of a RoHS restricted substance to 
provide certain functions in the products at hand is acceptable. The criteria specified in 
Article 5(1)(a) are understood to mean that where significant environmental, health and 
consumer safety benefits would be derived from the added function, that this could 
justify an exemption (depending as to how these benefits are to be weighed with total 
costs and benefits). However where technical aspects are enabled that do not relate to 
environment, health and consumer safety, RoHS does not specify if and how such 
impacts are to be considered. Where exemptions were issued when RoHS came into 
force, this is understood to have been done with the understanding that such 
exemptions would provide a transition period until products could comply with the 
substance restriction. However when a new product or a product with a new function 
and enhanced performance parameters is developed, there is no specification in RoHS as 
to whether and to how such functions should be taken into account. The evaluation can 
review whether a RoHS restricted substance supports a certain function, and if this is a 
significant difference in comparison to similar products on the market. However the 
evaluation cannot determine if the use of a RoHS restricted substance is an acceptable 
“cost” for the provision of a certain new function. In the exemption request at hand this 
is the case of the function colour gamut understood to be supported by the use of Cd 
QDs.  

It further needs to be noted that though for some products a single function may be the 
main factor influencing consumer choice; this is not always the case. For example, for 
medical diagnostics devices, it can be assumed that all medical facilities shall prefer a 
device, which enables better diagnostics, should this be possible with higher colour 
gamut. Though some facilities may not be able to afford such a device in lack of 
sufficient finances, it is assumed that at least for most facilities, better diagnostics shall 
be the key function influencing product choice. In contrast, as is apparent by the wide 
range of displays for sale, different consumers can be expected to have very different 
preferences in relation to displays.  

Though such questions are understood to be of importance, they are beyond a 
scientifically based assessment of the exemption and thus could only be taken into 
consideration in the course of the decision process of the EC and of the European 
Parliament, related to the requested exemptions. 

As for aspects raised by KEMI, as to how the comparison of products should be 
undertaken, the consultants generally agree that a technology needs to be evaluated in 
the context of the product in which it is being used. However, in the consultants’ 
perspective the “swap” comparisons made enable an understanding of the comparative 
potential of Cd-free and Cd-based QDs in displays and are thus understood to support 
the significant difference between each technology’s performance capabilities. The swap 
method allows understanding the potential of a technology within a specific product, 
and in this sense serves its purpose. However, for other technologies, comparisons of 
this sort are more complicated as it is not straightforward to distinguish between the 
functions enabled by the technology and by functions enabled or supported by other 
components. In such cases it seems that at present only a comparison on the product 

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level is appropriate. Provided information shows that some of the other technologies 
may provide sufficient alternatives in terms of colour gamut. However, the current 
inability to compare energy efficiency aspects as well as other aspects that may be of 
importance does not allow the consultants to conclude, which of the display types would 
be understood to have a significantly improved performance in relation to all relevant 
aspects. Thus the basis of available data, does not support other conclusions than those 
specified. 

5.6.6 

Exemption Wording Formulation  

When asked as to the wording proposed by the consultants in the 2013-2014 report, 3M 
DMSD95 stated that it agrees with a split of the exemption according to application field 
(between SSL and display lighting applications). They specify the following wording as 
one that best covers the display lighting application: 

“Cadmium in downshifting cadmium based semiconductor nanocrystal quantum 
dots for use in display lighting applications (< 0.2 μg Cd per mm² of display screen 
area)” 

3M DMSD further raises the “repeated delays of QD manufacturers to bring a non-Cd 
solution to the market” and the lacking availability of non-Cd QDs on the open market to 
support a 5 year termed exemption duration. It is further explained that 5 years will be 
needed for development of film formulations and reliability and performance testing (of 
the film and in devices such as televisions), once non-Cd QD materials become freely 
available on the market in sufficient quantities. 

In this respect, the consultants would like to note that both applicants have specified 
that CdQDs currently in use in displays on the market all use CdSe. In this sense the 
exemption could be specified to CdSe, as all provided comparisons are understood to be 
relevant for displays using CdSe QDs. Though the current Cd QD configurations result in 
significantly different amounts of Cd in the final product, in the consultants’ view, if an 
exemption is to be granted, it should not be limited to a certain configuration. This 
aspect was discussed in the initial review and is also supported by QD Vision’s statement, 
that:  

“on-edge cannot serve all markets. Display trends, including the desire for thinner 
bezels and HDR with its prescribed higher luminance requirements, are driving a 
strong market shift to direct-lit backlight technology – which requires the use of 
an on-surface QD configuration… Beyond televisions and monitors, most hand 
held-devices also place a premium on thin form-factors and bezels. And while QD 
Vision is working to miniaturise its on-edge technology, the implementation is 
unlikely to be sufficiently thin for such important applications. Until the advent of 

95 Op. cit. 3M DMSD (2016a) 

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an on-chip solution – which could come out of our on-edge development – such 
displays require the availability of an on-surface solution.”96  

5.6.7 

Conclusions 

Article 5(1)(a) provides that an exemption can be justified if at least one of the following 
criteria is fulfilled:  

 

 
 

their elimination or substitution via design changes or materials and 
components which do not require any of the materials or substances listed in 
Annex II is scientifically or technically impracticable;  
the reliability of substitutes is not ensured;  
the total negative environmental, health and consumer safety impacts 
caused by substitution are likely to outweigh the total environmental, health 
and consumer safety benefits thereof.  

For the first criteria, elimination or substitution, the colour gamut performance is 
understood to be the function differentiating between various types of displays. The 
information made available shows that CdSe quantum dots can be applied in displays, 
resulting in higher performance in terms of colour gamut. This is based on the results of 
a number of “swap” comparisons, in which the performance of a TV using a CdSe QD film 
was compared with that of the same TV using a InP QD film. In this sense, it can be 
concluded that in such cases the CdSe QD film used showed advantages related to the 
performance criteria colour gamut over the InP QD film used.  

On this basis it is observed that CdSe QDs can be used in displays to provide higher 
colour performance, however these results need to be considered with caution. 
Comparing results shows that the standard used for comparison may affect the results or 
at least their significance. From results of the “swap” comparisons it can be concluded 
that when CdSe QD films and InP QD films are compared in the same displays, that CdSe 
QDs always have a higher colour gamut performance. However the significance of this 
performance depends on the standards used for the comparison and is more significant 
in two cases (NTSC and Rec 2020) and less significant in another (DCI-P3). Results of 
general display comparisons can be used to understand this aspect in relation to other 
technologies (i.e., other than quantum dot technologies). On the basis of available 
information it was concluded in the evaluation of 2013-2014 that Cd QD technologies 
showed a colour gamut preference in comparison to other technologies available at the 
time. However, results of general comparisons made available at present show that 
there are some new technologies that may provide comparable or better performance. 
The NTSC results for TriGain phosphor, ß-sialon phosphor and SrGa2S4 phosphor show a 
comparability or a preference. The DCI-P3 results show comparability for IPS quantum 
and for Hi-performance phosphors. However as already stated above, it has been 
observed that higher performance in relation to one standard does not guarantee higher 

96 Op. cit. QD Vision (2016c) 

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performance in others. Thus it is difficult to conclude as to the colour gamut 
performance of CD QD technologies in relation to such newer technologies. 
Furthermore, all of these technologies are understood to be relatively new and it is not 
clear if all are in use in products currently available on the market. Where results relate 
to actual displays (iMac, LG 4 smart-phone), these are of smaller sizes, possibly affecting 
comparability as the scalability of such technologies is not clear, nor are other 
performance aspects. This hinders further comparison in relation to the other criteria 
(for example reliability, environmental impacts). 

As is apparent from data both for these phosphors and for the various QD displays, the 
market is observed to be very dynamic and the preference of a certain technology today 
should not be assumed to remain a constant for the long term.  

Though for some cases it is observed that CdSe QDs provide better performance than 
other technologies, it is neither possible to conclude whether this is relevant only for InP 
QD technologies or for all other technologies, nor whether the difference in 
performance is significant enough to justify an exemption on its own. 

As for the second criterion, in terms of reliability, the available data and particularly the 
market availability of displays using various technologies suggests that their reliability is 
sufficient for placing a product on the market, though it cannot be concluded from 
available data if the reliability is comparable for all displays in terms of expected service 
life. The applicants also both refer to long service lives of the CdQD components (films, 
optical tubes) of 30,000 hrs and above. In this sense, it is assumed that even if the 
display life is in some cases shorter, this could not necessarily be attributed to the use of 
the QD technology within the display. 

The third criteria relates to possible impacts on consumer safety, on health and on the 
environment. These are to be compared between the application relevant to the 
request and its possible alternatives.  

In relation to consumer safety, the Engler et al. LCA states “…These loading levels of Cd 
overstate the exposure potential to a toxic form of Cd. Unlike CFL light sources, there is 
no mechanism for the release of the QD material from the display itself. The QD 
materials are non-volatile and are further incorporated into a polymer matrix as a 
homogenous material (and then either placed between low-permeability barrier films or 
in the case of the on-edge optic manufactured by QD Vision, encapsulated in a 
hermetically-sealed glass tube).”97 Nanoco98 points out for example that “There is still a 
risk to the worker/consumer/environment if the device becomes damaged, e.g. (for QD 
Vision’s technology) if the fragile glass capillary component breaks, in a house fire, or in 
landfill.” However, the consultants understand the case of a “house fire”, in which a Cd 
QD display is damaged and results in emissions and possible impacts on consumer 
safety, health and the environment to have a relatively low likelihood. In relation to 

97 Op. cit. Engler et al. (2015) 
98 Op. cit. Nanoco (2016a) 

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consumer safety the consultants can follow QD Vision’s statement that “the risks of InP 
and CdSe should not be exaggerated – particularly in the QD form that they have they 
present no hazard to the user” 99. 

As for health aspects, from the data available as to toxicity, it is difficult to differentiate 
between InP and CdSe QD applications in terms of the risks of possible health impacts. A 
comparison with other technologies is currently not possible on the basis of available 
data, as it would require knowledge as to substances used in relevant components and 
the risks of emissions thereof. In contrast, it can be followed that in some cases, the 
colour gamut function can serve to create environmental benefits, i.e., when these 
technologies are used to improve medical diagnostic capabilities. In other words where 
colour gamut can be achieved by a display technology in medical diagnostics devices, 
possible benefits to health could also be considered. As it can be understood that 
additional technologies may also achieve good colour gamut, it can however not be 
concluded whether such benefits could only be attributed to displays using CdSe QDs. 

Finally, in terms of environmental impacts, it is observed that for displays where data is 
available, that the use of CdSe QD films can result in higher energy efficiency which 
could lead to lower emissions, thereunder Cd emissions, from energy supply. Though 
comparing different displays on the market, as a product, shows that in some cases InP 
QD film displays perform better in this regard than some CdSe displays, the “swap” 
comparison allows concluding that these differences are related to other components of 
the display design and not to the different technologies themselves. In “swap” 
comparisons CdSe QD films showed consistent results in terms of higher energy 
efficiency, though the difference varied between different displays (between 22% to 28% 
lower consumption displays of varying sizes). On this basis it can be concluded that CdSe 
QD can provide higher energy savings in comparison to InP QDs when used in a certain 
display. As for other display technologies, though there appear to be display 
technologies that could compare with Cd Qds in terms of colour gamut, the data made 
available does not allow concluding if these technologies would also have a similar 
potential to reduce energy consumption or if the opposite would occur. Data has not 
been made available for such technologies and a conclusion in this respect is not 
possible at present. 

It can be understood that there are displays on the market with better performance in 
terms of energy consumption, when comparing displays of different sizes and of 
different colour performance. However when these aspects are held constant and 
particularly for consumers looking to purchase a display with higher colour gamut 
performance, the available information suggests that the use of CdSe QDs could allow 
reducing the energy consumption of the display. It has been demonstrated that this 
reduction is significant when comparing displays using CdSe QD technologies and 
displays using InP QD technologies. It is currently not possible to conclude whether this 

99 Op. cit. QD Vision (2015) 

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reduction would also be relevant (or significant) in comparison to all other technologies. 
The 2013-2014 evaluation showed energy benefits of above 10% in relation to other 
technologies available at the time100. It is apparent that there may be some new 
technologies with comparable colour gamut performance, which are starting to emerge 
in products on the market. Available data however does not allow a conclusion as to the 
energy efficiency of such technologies in comparison to Cd QD displays.  

On the basis of available information and data it can be concluded that the use of CdSe 
QD technologies in displays can provide a higher colour gamut performance and a higher 
energy efficiency. This conclusion can be drawn in relation to older technologies 
available on the market and in relation to InP quantum dot technologies (though the 
significance of colour gamut performance differences may vary). As for newer 
technologies, information is only available as to colour gamut performance and does not 
allow a comprehensive conclusion at present. As such technologies can be understood to 
be in their first market stages (used in first products) or still in development and as data 
does not allow comparing aspects such as reliability, scalability and energy efficiency, it 
is recommended to grant a short term exemption, to allow monitoring the suitability of 
such technologies as alternatives in the near future.  

Further thought may also need to be given to how an alternative and the baseline 
respectively are defined. Where it can be followed that the colour gamut function has a 
significant influence on consumer preferences, this aspect may serve to define what 
types of displays are to be considered as appropriate alternatives in relation to the first 
criteria, which relates in the end to the functionality.  

It is beyond the scientifically based assessment mandate of the exemption evaluation to 
conclude whether the use of cadmium as a RoHS restricted substance to enable a certain 
function or property (colour gamut) is an acceptable cost therefor. There is a wide 
variety of displays used in other categories (televisions, telecommunications and displays 
of other EEE) and the fact that a certain function could be added does not allow 
concluding whether this function would comprise the main preference influencing 
consumers purchasing choices. Though this aspect is beyond the scope of this review, in 
the consultants’ opinion it is an aspect to be considered as part of the decision process 
on whether to grant the requested exemption or not and what its duration should be. 

6.0  Cadmium Quantum Dots in Lighting 

Applications 

In the 2013-2014 evaluation of these requests, it was mentioned that QD were being 
developed for use for solid state lighting (SSL) applications. At the time it had been 

100 Op. cit. Baron et al. (2014) 

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stated that there were no articles on the market using either Cd-based or Cd-free QD, 
however it was stated that these should come onto the market shortly. As lighting 
applications have a very wide range of applications (form and dimension, power rating, 
lumen output, efficacy, colour performance, area of application, CRI etc.), it was 
concluded at the time that without understanding the area of applicability, a comparison 
of parameters would not enable understanding whether QD lighting technologies had 
advantages over conventional ones. The applicants and stakeholders have thus been 
requested to provide information as to changes in the market status of these 
technologies and as to the comparative performance thereof. Information made 
available in this respect is presented in the following sections. 

Technical Background 

6.1 
According to Lumileds101, conventional solid-state lighting technology is based on blue 
LEDs exciting a garnet and red phosphor (phosphorescent light downconverter) to 
generate green, yellow and some red light, which is mixed to form white light for 
illumination purposes. To create warm white light (CCT<3500K) with a high quality of 
light (CRI>90) it is necessary to add a significantly higher amount of red phosphor of 
longer wavelengths to produce the warm tones missing from the garnet phosphor 
spectrum. The problem with conventional red phosphors is that they have a broad 
spectrum and are therefore less efficient than green phosphors. LEDs with CRI>90 have 
lower luminous efficiency than LEDs with CRI of 80 because of the greater fraction of LED 
emission spectra needed in the far-red wavelength region. The broad spectrum of 
conventional red phosphors exacerbates the drop in luminous efficacy as the emission 
further reaches deep red and infrared wavelengths where the eye sensitivity is low. 
Similar to incandescent bulbs, a significant part of the generated light is wasted as 
infrared radiation.  

Lumileds contends that quantum dots (QDs) are a relatively new material class that, like 
phosphors, down-convert light from higher energy wavelengths of typically blue light to 
lower energy wavelengths of green or red light. Key characteristics of quantum dots are 
their potentially very high efficiency, their narrow emission spectrum, and that their 
emission frequency can be accurately tuned across the entire visible spectrum. The 
narrow emission spectrum prevents the needless generation of invisible infrared 
radiation. No other downconverter exists which exhibits narrow emission (<35 nm 
FWHM), is emission tunable to within a wavelength in the range of few nm, and has 
extremely high photoluminescence quantum efficiencies, both at room temperature and 
LED operating temperatures.102 

101 Lumileds (2015a), Lumileds Germany GmbH, Input for stakeholder consultation for RoHS exemption 
requests 2013-2 and 2013-5, submitted 14.12.2016, available under 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Quantum_Dot_Evaluation/2
0151214_Oeko_Institut_consultation.pdf  
102 Op. cit. Lumileds (2015a) 

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Lumileds103 explains that QD LED packages are relevant for lighting areas where colours 
are to be rendered accurately, i.e. when we want our surroundings to look natural and 
realistic. High colour rendering / quality of light is not limited to a specific application. 
Examples of specific applications are for example: 

  Bathrooms (to be able to accurately apply makeup, to accurately see the 

colour of your skin, teeth etc. in the mirror); 

  Living rooms, dining rooms (to accurately see the colour of food, artwork, 

people); 

  Museums (to accurately see the colour of paintings); 
  Retail/shops (to accurately and appealingly reproduce the colour of objects 

for sale); 

  Hospitality/hotels (to appealingly represent the colours of artwork, furniture, 

and people); 

  Stadium lighting (to accurately represent the colours of the athletes both to 

the audience and the TV cameras); and 

  Surgical lighting (To ensure the colours of tissue are accurately represented 

indicating to the surgeon the oxygenation level of tissue. In this instance high 
efficiency lighting has added importance beyond simply energy savings; it 
means the surgeon does not sweat under the heat of the lamps generating 
the intense light required for surgery). 

Lumileds Cd QD LEDs are intended to be used in retrofit lamps, LED modules and LED 
luminaires such as A-style bulbs, candle lamps, spotlights, downlights, troffers, and tube 
LEDs (TLEDs). 104 

6.1.1 

Standards and Methods for Comparing Lighting 
Performance  

According to Nanoco105, the main measures for comparison of LED lighting products are: 

  Correlated Colour Temperature (CCT). The colour temperature of the light 
emitted from an ideal black body is defined as its surface temperature in 
Kelvin. Standard incandescent lamps have a CCT of around 2400K. Standard 
LED and fluorescent lights usually have a much higher CCT, which gives a 
bluer light. 

  Colour Rendering Index (CRI) is a quantitative measure in % terms of the 
ability of a light source to show the colours of various objects correctly in 
comparison with an ideal or natural light source. 

103 Lumileds (2016b), Answers to 1st Clarification Questionnaire Regarding CdQD Exemptions, submitted  
18.4.2016 
104 Op. cit. Lumileds (2016b) 
105 Op. cit. Nanoco (2015a) 

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  Luminous Efficacy (LES) is the amount of light flux produced for the electrical 

power consumed, measured in Lumens per Watt (Lm/W). 

  The R9 value is a measure of the red component in a light, which is essential 
for producing more natural colours from artificial lights. The R9 value is not 
included in the standard CRI index. 

106. LES is calculated by multiplying 

Nanoco explains that when designing spectra for general lighting purposes, there is often 
a trade off in the lamp efficiency (LES) and the CRI Ra
the spectral power distribution (SPD) of the measured lamp source by the human eye 
sensitivity curve, which is particularly sensitive in the green part of the spectrum around 
555nm, but tails off rapidly in the blue and red regions. CRI Ra on the other hand has 
particular sensitivity at different parts of the visible spectrum and in particular a 
significant component in the red region. This sensitivity also changes as the effective 
colour (CCT) of the emitted light changes. In addition to the CRI Ra sensitivity, a particular 
component of the metric known as the R9, which represents the ability of a light source 
to accurately represent deep red colour tones is also gaining prevalence in the lighting 
industry, with regulations such as Energy Star107 requiring that this specific figure is 
quoted. R9 is far more sensitive than the CRI Ra metric, particularly in the red region of 
the spectrum. This means that in order to maximize the colour rendering properties of a 
light source (CRI values >90) the LES must be sacrificed as wavelengths in the red part of 
the spectrum need to be covered, where the eye is less sensitive. 108 
According to Lumileds109, in the case of lamps producing white light for general 
illumination, product performance is measured by the following parameters. All four 
parameters, CCT, CRI, efficacy and luminous flux, should be measured according to the 
international standard CIE S 025, issued by the International Commission on Illumination.  

  Luminous flux (the amount of visible light generated by the lamp); 
  Luminous efficacy (the luminous flux divided by the electric input power); 
  Colour temperature (CCT, how warm or cold/blue-ish the light appears); and 
  Colour rendering index (CRI, how well a light source reproduces the colours of 

the objects it illuminates). 

Lumileds110 notes that there is an inherent trade-off between colour temperature (CCT), 
colour rendering index (CRI) and luminous efficacy. This is due to the fact that the human 
eye is not equally sensitive to all wavelengths, i.e. to all colours of light. Going from CRI 

106 Referenced in Nanoco (2016b) as Y. Ohno, “Spectral design considerations for white LED colour 
rendering,” Opt. Eng., vol. 44, no. 11, p. 111302, 2005. 
107 Referenced in Nanoco (2016b) as Energy Star, “ENERGY STAR® Program Requirements for Televisions 
Partner Commitments,” 2008 
108 Op. cit. Nanoco (2016b)  
109 Op. cit. Lumileds (2015a) 
110 Op. cit. Lumileds (2015a) 

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80 to CRI 90, all other parameters being equal is thought to result in a 20% decrease in 
luminous flux111. 

Lumileds states that a suitable colour temperature for benchmarking is 2700K (warm 
white), which is equivalent to the colour temperature of incandescent light bulbs and is 
frequently recommended for residential use112. CRI values of 90 and an R9 value of 50 
are appropriate. The EU regulation 1194/2012 requires a minimum CRI of 80 (for 
residential use), but better colour rendering properties are recommended112. Lumileds 
agrees with the parameters provided by Nanoco. Luminous efficacy (in lm/W) is the key 
environmental parameter. CRI, CCT and R9 describe product performance, and only 
products with equal performance should be compared. 113 

6.2 

The Market Availability of Quantum Dot Lighting 

The applicants, QD Vision and 3M DMSD have not provided detailed information as to 
lighting applications in their recent documents. 
Nanoco114 provides some detail as to lighting applications containing QDs that are 
available on the EU market. 

Table ‎6-1: Lighting Applications Containing QDs that are Available on the 
EU Market 

Notes: The Nexus Par 30 LED was discontinued in 2013.The Zylight F8-D LED Fresnel is the only Cd-based 
lighting product we have found available in the EU. However, this is a very expensive (>€2000ea) specialist 
theatrical spotlight for professional use only. 
Source: Nanoco (2015a) 

Nanoco also states that it demonstrated 4 different product ranges at the Lux Live 
exhibition this year. A panel lamp, a strip light and a spot light for domestic and 
commercial use were shown, each of which will be available in 3 colour temperatures. A 
horticultural lamp was shown in a strip light version and a panel lamp version is also 
being developed. 115 

111 Referred to in Lumileds (2015a) as http://www.ledsmagazine.com/articles/2013/01/lighting-coalition-
asks-epa-to-lower-energy-star-efficacy-specsfor-high-cri-lamps.html   
112 Referred to in Lumileds (2015a) as US Department of Energy, “Energy Efficiency of LEDs,” 2013 
113 Op. cit. Lumileds (2015a) 
114 Op. cit. Nanoco (2015a) 
115 Op. cit. Nanoco (2016a) 

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Lumileds116 manufactures LED modules and not Cd QD materials or Cd QD lighting end-
products (i.e. lamps or luminaires to be sold to the final consumer). Lumileds is not 
aware of any additional lighting products employing quantum dot technology having 
been placed on the market. LED products using quantum dot technology – with or 
without cadmium – are currently not widely available. Lumileds intends to launch LED 
packages containing cadmium-based quantum dots in 2016. However, the uncertainty 
around this exemption leads to reluctance by lamp and luminaire manufacturers to 
invest into the technology, to explore its full potential and to develop products.  

Lumileds expects that its LED packages shall be used in a wide range of lamps and 
luminaires. However, as a component supplier Lumileds cannot comment on the exact 
uses of such applications. 117 

Comparative Performance of Quantum Dot Lighting 

6.3 
CREE, Inc.118 supports the request in relation to lighting applications. CREE has fabricated 
and tested a variety of white LEDs (i.e. those with colour points on or near the black-
body locus) which contain red-emitting (600-630nm) Cd-based QDs. An example 
spectrum of a warm-white (~2700K) QD-LED is compared with that of a conventional 90 
CRI (colour rendering index) all-phosphor LED in Figure  6-1. CREE explains the spectral 
efficiency of the QD-LED is ~18% higher than its all-phosphor counterpart, which 
translates into a corresponding efficacy gain when the QD quantum yield is comparable 
to that of the phosphors. 

116 Op. cit. Lumileds (2015a) 
117 Op. cit. Lumileds (2016b) 
118 CREE (2016), CREE Inc., Santa Barbara Technology Center, Consultation Questionnaire Regarding Cd 
Exemptions, submitted 11.1.2016, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Quantum_Dot_Evaluation/C
REE__RoHS_Cd_exemption_consultation.pdf  

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Figure ‎6-1: Spectrum of a Warm-white (2700K, 92 CRI) LED Containing Cd-
based QDs (red line), vs. an LED with Conventional Red Phosphor (Green 
Line) at the Same Colour Temperature and CRI 

CREE notes that the human eye response is overlaid for reference. The QD-containing LED has a ~18% 
higher spectral efficiency due to its low emission in the near-infrared. 

Source: CREE (2016) 

CREE119 claims to have evaluated both Cd-based and Cd-free QDs which emit red light. 
CREE explains that synthesized Cd-based QDs currently have quantum yield (blue to red 
light down-conversion efficiency) values of >90%, which is on par with conventional 
green/yellow and red phosphors. Meanwhile according to CREE, Cd-free QDs (e.g. InP-
based) have been observed to have quantum yield values of <75%, which, combined 
with their broader (>45 nm FWHM) peak width, results in lower LED efficacy compared 
to Cd-based QDs. Given the current state of Cd-free QDs and their rate of development, 
CREE estimates that they will be precluded from practical use in SSL applications for the 
next >5 years. CREE values luminous efficacy as the most appropriate metric for 
evaluating the economic and environmental impacts of emerging solid-state lighting 
technologies, and provides Table  6-2 to compare luminous efficacy of various light 
sources they have tested. 

119 Op. cit. CREE (2016) 

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Table ‎6-2: Input Efficacy Values for Calculation of Cd Emissions 
Reductions, for LEDs at 3000K CCT and 90 CRI Ra & 50 CRI R9 

Source: CREE (2016) 

According to Nanoco120, QDs are most effective in lighting applications where a high 
degree of spectral tunability is required, due the inherent increased emission tunability 
of the QD nanocrystals compared to other lighting technologies. For white lighting 
applications, QDs can be used to tune the colour temperature, for example to replicate 
natural daylight or to produce “mood lighting”, for example in shops and restaurants. 
Nanoco121 provides comparative data as to the efficacy and colour performance of 
various QD lighting applications, reproduced in Table  6-3.  

Table ‎6-3: Comparison of Products Available in the EU 

The Nexxus Par 30 LED was discontinued in 2013 and never replaced. The Zylight F8-D LED Fresnel is the 
only non-Nanoco lighting product we have found available in the EU that has claimed to use QDs. This is a 
very expensive (>€2000ea) specialist theatrical spotlight for professional use only. However, when a sample 
was tested by Nanoco it was found to contain no cadmium. It was found to contain significant levels of 
Aluminium, Yttrium, Gallium and Calcium. The spectrum of the light showed broad emission, other than for 
the blue from the LED, rather than the narrow peaks associated with QDs. 
Source: Nanoco (2016a) 

In a later communication, Nanoco122 provides additional comparisons reproduced in the 
following tables. Table  6-4 shows a comparison of two of the lamps shown in Table  6-3 

120 Op. cit. Nanoco (2016b) 
121 Op. cit. Nanoco (2016a) 
122 Op. cit. Nanoco (2016b) 

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with an OLED lamp, which has similar performance parameters. Table  6-5 shows a 
comparison of a Cd-free QD LED with an HPS lamp, which has similar performance 
parameters.  

Table ‎6-4: Comparison of Lighting Products with Similar CCTs, Similar to 
that of Daylight 

Source: Nanoco (2016b) 

Table ‎6-5: Comparison of a High Pressure Sodium Lamp (HPS) with an 
Alternative Developed by Nanoco 

 Source: Nanoco (2016b) 

Nanoco123 also states that high performance phosphors are also being investigated for 
lighting applications. One paper demonstrates that Sr[LiAl3N4]:Eu2+ phosphor can 
provide a 14 % improvement in luminous efficacy compared to a commercially available 
high CRI LED, while GE claims a 32 % improvement in luminous efficacy at a CCT of 4,000 
K for its TriGain™ phosphor, compared to a conventional high CRI LED. The device with a 
CCT of 4,000 K had a high CRI of 90, a luminous efficacy of 168 lm/W and an R9 value > 
90.  
Nanoco124 provides further details as to Cd-free QDs used in alternatives for high 
pressure sodium (HPS) lamps and for horticultural lighting. As detailed information is not 
available to allow a comparison of CdQD lighting applications for these applications, the 
information is reproduced in Appendix  A.2.0. 
Nanoco125 argues that, while cadmium-based QDs could be used to give similar lighting 
performance and characteristics, the RoHS Directive makes it clear that such restricted 
materials should not be used where alternatives exist. The current situation is that there 
are no cadmium QD lighting products on the EU market, while cadmium-free QD 

123 Op. cit. Nanoco (2016b) 
124 Op. cit. Nanoco (2016b) 
125 Op. cit. Nanoco (2016b) 

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products have already been launched. Nanoco believes that in this situation, there is no 
justification for extending Ex. 39 for all LED lighting products as this would only serve to 
promote the development and introduction of new cadmium based products – the 
precise opposite of what the RoHS Directive is intended to achieve. It would, of course, 
still be possible for manufacturers to develop cadmium QD lighting technology aimed at 
specific commercial lighting applications where they can positively prove that suitable 
alternatives do not yet exist and therefor apply for new, specific exemptions for those 
products in line with the RoHS Directive requirements. 
Lumileds126 confirms that they are currently not aware of any products on the market 
containing CdQds, though they expect such products to come on the market in 2016. 
Lumileds claims that luminous efficacy improvements are especially significant for warm-
white lamps with a high quality of light (i.e. good colour rendering properties). The 
higher the CRI, the larger the red content and the greater the visual impact and benefit 
of the quantum dots. Based on internal data, Lumileds expects that the efficacy 
improvements presented in Table  6-6 can be achieved within the next two years (at a 
given CCT/CRI combination, relative to current conventional phosphors). 
In a later communication, Lumileds127 explains the advantage of Cd QD LEDs is not the 
spectral output in itself, but the higher luminous efficacy at given CCT/CRI combinations. 
The same spectral output can also be reached with conventional phosphor technology. 
This creates hardly visible red and invisible infrared light and wastes energy. With 
conventional phosphors it is currently not possible to avoid this completely, and 
therefore the luminous efficacy is lower compared to the Cd QD LEDs. The luminous 
efficacy gains (of Cd QD LEDs compared to conventional phosphor LEDs) will therefore 
be highest at lower CCT and higher CRI values. Table  6-6 shows that also at higher CCT 
(4000K / neutral white) there is still a significant luminous efficacy gain vs. conventional 
phosphor LEDs. 

Table ‎6-6: Expected Efficacy Improvements that can be Achieved within the 
Next Two Years in CdQD SSL 

Source: Lumileds (2015a) 

Lumileds128 further provides data comparing two LEDs, with and without Cd QDs to a 
similar 60W incandescent lamp (CCT of 2700K, CRI of 90), which is reproduced in 

126 Op. cit. Lumileds (2015a) 
127 Op. cit. Lumileds (2016b) 
128 Op. cit. Lumileds (2015a) 

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Table  6-7.  The data shows the power consumption of the LED lamp containing quantum 
dots to be 2.20 W lower than that of the LED lamp using conventional phosphors. 
Lumileds states that the resulting savings by far outweigh any potential negative health, 
safety and environmental effects that cadmium inside the products may have. 

Table ‎6-7: Performance of two LED Lamps (with and without quantum dots) 
with a Similar Performance 60W Incandescent Lamp 

Source: Lumileds (2015a) 

In terms of reliability, Lumileds129 explains that until now, quantum dots could not be 
used directly in LED packages because their reliability and performance at the high 
operating temperatures encountered in LED packages was not sufficient. However, new 
developments allow quantum dots to be placed inside the LED package, directly on top 
of the semiconductor material (i.e. the LED die), which will finally enable their use in LED 
lighting. At the moment, the only type of quantum dot that can be used in this 
configuration and has the aforementioned advantageous properties is a cadmium 
containing quantum dot. 

Lumileds was asked to substantiate its information to allow a better understanding of 
the applications for which Cd-QDs are expected to be developed, i.e., areas of 
application where the advantages in terms of warmer light and higher efficiency are 
significant in relation to existing applications. Lumileds130 provided the Table  6-8 to allow 
a better understanding of the parameters compared in their initial documents. In this 
respect Lumileds explains that the efficiency gains from the use of quantum dots are 
biggest for warm-white, high CRI products with a high quality of light, i.e. with similar 
light quality properties as that of a 60W incandescent lamp (CCT of 2700K, CRI of almost 
100). This used to be the most common lamp until it was phased out by legislation, and 
many consumers are still trying to find replacement lamps with equal light properties. 
Though the data is given for an example lamp, it is explained that it is derived from the 
single LED package. The LED packages used in this reference lamp determine the 
performance improvement associated with the use of Cd QD LEDs. They can be used in 
other lamp/luminaire configurations without any changes to the LED package. 

129 Op. cit. Lumileds (2015a) 
130 Op. cit. Lumileds (2016b)  

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Table ‎6-8: Parameter Specification for Conventional LED and Cd QD LED 
Used in Lumiled LCA Comparison 

Source: Lumileds (2016b) 

Lumileds131 explains that the parameters are specified on the basis of their research and 
testing. Lumileds produces LED packages and not final applications. In this sense, 
Lumileds confirms that it has not tested lamps, but rather LED modules. These had CCT 
of 3000K, CRI of 90 and R9 of 50. Light output is 495lm. The test results of the 
engineering samples confirm the expected gains in luminous efficacy and thereby 
confirm that the reference lamp is also representative (in terms of expected luminous 
efficacy gains) for other types of lamps and luminaires in different configurations, with 
similar light quality properties. 

Environmental Arguments 

6.3.1 
Lumileds132 quotes UNEP133, explaining that “Electricity for lighting accounts for between 
15% (UNEP, 2014) and 19% (IEA, 2006) of global electricity consumption and between 5 
and 6% of worldwide CO2 emissions. A global transition to widely available efficient 

131 Op. cit. Lumileds (2016b) 
132 Op. cit. Lumileds (2015a) 
133 Refered to in Lumileds (2015a) as Sustainable Energy for All Initiative, United Nations, “Global Energy 
Efficiency Accelerator Platform – Lighting”, 
http://www.se4all.org/energyefficiencyplatform/lighting/, accessed November 25, 2015 

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solutions in all lighting sectors (residential, commercial/industrial and outdoor) by 2030 
could reduce electricity demand for lighting by more than 32%, and avoid 3.5 Gt of CO2. If 
the world leapfrogged to LED lamps in all sectors, it would reduce global electricity 
consumption for lighting by more than 52% and avoid 735 million tonnes of CO2 
emissions each year”. In this respect Lumileds states that the application of quantum dot 
technology will accelerate this transition and further increase the potential savings of 
current LED lamps in electricity consumption and resulting CO2 emissions, as outlined 
below. 
According to Lumileds134, as with any other technology, the environmental impact of LED 
light sources is measured by the material and energy resources used over the entire life-
cycle of the product (production, use, recycling and/or disposal). In the case of all 
lighting technologies (incandescent, fluorescent, discharge, LED), the total life-cycle 
consumption is dominated by the electricity consumption during the use phase135. As 
noted by the U.S. Department of Energy, “the greatest environmental impact after 
energy in-use for the LED sources is the aluminium heat sink, which would be reduced in 
size as the efficacy increases, and more of the input wattage is converted to useful 
lumens of light (instead of waste heat).”136 Most other parameters will not change 
significantly due to the introduction of quantum dots (e.g. energy consumption of LED 
die and package production, material use for LED lamp). Consequently, the most 
important parameter by far for assessing environmental performance of a light source is 
its luminous efficacy, i.e. the ratio of visible light output (luminous flux, measured in 
lumens) and power consumption (in watts). 137 
Lumileds138 explains that as quantum dots LEDs show an increase in efficacy compared 
to current conventional phosphor LEDs, more of the input wattage is converted to useful 
lumens of light (instead of waste heat), resulting in a decrease in the heat sink size. The 
thermal management of current conventional phosphor and quantum dots LED lamps 
have been modelled to estimate the volume, as well as the weight of the heat sink 
needed to dissipate this heat, and is reproduced in Figure  6-2. 

134 Lumileds (2016a), Comparative life cycle assessment of LED lamps based on cadmium containing 
quantum dots and conventional phosphors prepared for Lumileds, submitted 8.1.2016, available under 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Quantum_Dot_Evaluation/L
umileds_20160108_LCA_Results_final.pdf  
135 Referred to in Lumileds (2015a) as US Department of Energy, “Life-Cycle Assessment of Energy and 
Environmental Impacts of LED Lighting Products”, 2013 
136 Referred to in Lumileds (2015a) as US Department of Energy, “Life-Cycle Assessment of Energy and 
Environmental Impacts of LED Lighting Products - Part 2: LED Manufacturing and Performance”, 2012  
137 Op. cit. Lumileds (2016a)  
138 Op. cit. Lumileds (2015a) 

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Figure ‎6-2: Comparison of Waste Heat and Waste Sink Weights of LED 
Lamps 

Weights of the heat sink used in the LCA: 

Source: Lumileds (2015a) 

CREE139 also explains that emerging quantum dot materials in solid state lighting will 
raise luminous efficacy by up to 20% over conventional phosphor-down-converted LEDs, 
thereby resulting in lowered cost of ownership and greatly reduced pollutant emissions 
from electricity generation. CREE estimates that the reduction in Cd emissions enabled 
by QDs in LEDs used for a 10-year warranty period could be >18 times that of the Cd 
content sequestered in the LEDs themselves. CREE declines to comment on display 
applications. However, noting that the efficacy gains enabled by QDs in LEDs for solid-
state lighting will also benefit display (e.g. large-format TV) efficiency, since most LCD 
displays are backlit with LEDs.  

139 Op. cit. CREE (2016) 

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Exemption Scope and Wording Formulation 
6.4 
Lumileds140 states that the following wording is understood to be adequate: 

“Cadmium in components for lighting applications and display lighting applications, 
containing downshifting cadmium based semiconductor nanocrystal quantum dots, 
where the cadmium per display screen area is limited to less than 0.2 ug/mm².” 

Lumileds understands the concentration limit of 0.2 μg/mm² to be applicable only to 
display products and believes that, if a maximum limit for lighting applications were to 
be proposed, the exact definition and limit value would need to be reconsidered as the 
definition of display screen area is not applicable to lighting products. In Lumileds 
perspective, the terms “nanocrystal” and “quantum dot” seem redundant. At least one 
of the two terms should be removed. In addition, both terms are not clearly defined 
within the context of this regulation. This may lead to unnecessary uncertainty and 
misunderstandings. For the reasons stated in the letter of LightingEurope in response to 
consultations 2013-2 and 2013-5 (dated November 11, 2013)141, Lumileds believes it is 
preferable not to specify a maximum concentration and thus proposes the following 
wording: 

“Cadmium in light control materials used for lighting devices” 

CREE142 supports the use of the LED component-specific language proposed in the 2013-
2 application, namely “Cadmium in II-VI colour converting material (< 10 μg Cd per mm² 
of light-emitting area) for LEDs for use in solid state illumination or display systems”. 
CREE proposes that the LED light-emitting area be defined as the combined surface area 
of region(s) on an LED component where light down-conversion may occur. 

6.5 

Critical Review 

6.5.1 

REACH Compliance - Relation to the REACH Regulation 

See review in Section  5.6.1. 

6.5.2 

Scientific and Technical Practicability of Substitution 

The stakeholders describe the advantages of using quantum dot technologies for 
lighting. The main advantage of QD LED packages is understood to be that they can be 
used to produce light sources, with a warmer light and higher colour rendering 
properties, which are more efficient than other sources in terms of energy consumption.  

140 Op. cit. Lumileds (2015a) 
141 Referred to in Lumileds (2015a) as 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_IX/Request_2013-
2/20131111_Lighting_Europe_WG_Material_support_letter_RoHSexemption39_Ex_Re_2013-2-
5_final.pdf    
142 Op. cit. CREE (2016) 

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As the light emission of QDs can be tuned to produce a narrow and accurate spectral 
output, it is understood that light sources can be designed to emit more light in the 
relevant spectral output range of visible light, while decreasing losses to the invisible 
light range.  

In cases where warmer light and higher colour rendering are needed, a spectral output is 
usually sought stretching in to the range of red wavelengths. In conventional light 
sources, though the light source shall be designed to emit light in the visible red 
wavelength range, there shall also be light emitted in the non-visible range, some of 
which results in heat being radiated from the lamp and not just light. From the available 
information, it can be understand that QDs can be tuned, determining the wavelengths 
of the emitted light more accurately. This allows reducing the spectral output in the non-
visible range and thus also reducing losses to radiation (i.e. waste heat). Respectively, 
more of the power input is used to produce visible light and less is lost as non-visible 
light and heat, increasing the total efficiency of the lamp. As the waste heat is reduced, 
the size and weight of the lamp heat sink can also be reduced, this providing a further 
advantage in terms of the resources needed to manufacture the light source. 

The consultants can follow that in certain areas of application, where a spectral output in 
the red wavelength range is required, that QD LED packages may allow designing the 
spectral output more efficiently, reducing emissions in the non-visible light range and 
reducing waste heat of the light source. To establish however the magnitude if this 
advantage, it is necessary to compare between QD LED light sources and between other 
light sources, however, as described below, it is apparent that this needs to be done in a 
certain way, depending on the area of application. 

From the review of the information available, the consultants note when making 
comparisons, the application being compared is of importance to deduce how the light 
sources should be compared:  

  When a QD LED package is expected to be a substitute for lighting 

applications, which are also designed on the basis of LED packages, then a 
comparison on the component level of LED packages may suffice. This is 
based on the understanding that the packages shall be applied to the product 
in the same way (the same array) in order to produce a similar type of 
lighting. In this sense, the LED package can be seen as a smaller building block 
of the application, where both applications contain the same number of 
packages in the same array. 

  When however two LED products are being compared, which are assembled 
differently, it is possible that the number of packages used per product may 
differ and that the light output and light distribution from the two products 
may be different. In such cases it would not suffice to compare two modules, 
but rather the two products would need to be compared, taking into 
consideration the module comparison, but also the number and array of 
packages and the resulting light and its parameters. In such cases, the 
comparison needs to take into consideration that the light source may be 
different in terms of the resources (materials) from which it is composed. 

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83 

 
 
However the use of LED packages may simplify the comparison to some 
degree, in so far that there will be similarities in resource use related to the 
materials comprising the LED packages. 

  For similar reasons, where a QD LED package is expected to be a substitute 

for other light technologies (i.e., conventional technologies such as discharge 
lamps, but also more innovative technologies such as OLEDs), a comparison 
between the QD LED product and the product being replaced would be of 
relevance. The only exception to this rule would be in areas where the lamp 
technology to be replaced has been, or is about to be phased out. In such 
cases the comparison would be with other possible replacement alternatives 
and would be performed depending on their technology.  

With the different aspects related to light source comparison in mind, the data and 
information provided by Nanoco and Lumileds can be viewed with an aim to determine 
whether the advantages of Cd QD LED packages would justify an exemption from the 
RoHS substance restrictions. 

Nanoco provides data as to the performance of a number of Cd-free QD LED lighting 
products already available on the market. Nanoco also details a number of applications 
of relevance for Cd-free QD LED light sources, namely in horticultural lighting, as a 
substitute for HPS lamps and as panel lamps, strip lights and spot lights for domestic and 
commercial uses. As these lamps are understood to use other than Cd QDs, it is 
understood that they can be placed on the market regardless of whether the exemption 
is to be approved or denied. However, such light sources are an alternative that could be 
compared to Cd QD LEDs. Since they also use quantum technology to determine the 
spectral output, it can be assumed that the spectral output of light sources can also 
result in lower spectral losses and heat losses, thus enabling the production of more 
efficient lamps, at least in some areas of application.  

As Lumileds demonstrates, the energy efficiency advantage is not absolute but rather its 
magnitude is tied to the parameters of the designed light source. As is apparent from 
Table  6-9, the efficacy improvements for higher CRI and R9 values are significantly larger 
than for lower values. The efficacy also changes in relation to CCT, with higher efficacies 
expected for warmer light (or light with a lower colour temperature). 

Table ‎6-9: Expected Efficacy Improvements that can be Achieved within the 
Next Two Years in CdQD SSL 

Source: Lumileds (2015a) 

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This further supports that to Cd QD LED sources need to be evaluated in relation to the 
specific application, for which they are to be used. As observed from the table, in some 
areas, significant reductions of energy consumption could justify the use of a substance 
restricted by RoHS. However in others, where energy performance of light sources is 
comparable or where differences are less significant, this may not be the case. Thus the 
evaluation needs to consider the area of application. The data currently available, 
however does not allow a comprehensive comparison. In this respect, two types of 
comparison are understood to be of relevance at present. A comparison of Cd-based and 
Cd-free QD LED packages and a comparison of light sources based on QD LED packages 
with alternative light sources in relation to a specific application. 

Since both of these are quantum dot technologies a comparison on the package level 
could be relevant for establishing whether the technologies are comparable or whether 
one provides performance superior to that of the other. However the data currently 
available would not allow such a comparison as it is not available for both technologies 
in relation to the LED package.  

The data provided by Lumileds and by Nanoco would also not allow comparing Cd-based 
and Cd-free QD LEDs for a certain application as the two stakeholders have not provided 
data for a similar application. Even if this comparison were currently possible, a second 
stage would be to compare the applications in terms of the number of modules used and 
the various materials and resources used to manufacture the light source, as it could 
currently not be assumed that the light source is identical in all respects aside from the 
LED packages used.  

Finally, even if one could currently determine the superiority of one of these QD 
technologies, it would still be of importance to understand the planned area of 
application of the LED packages, as this shall determine what products are currently used 
for the same purpose on the market. Alternative light sources of the specific application 
area would need to be reviewed to understand their comparability with QD LED light 
sources. For example, Nanoco provides detail of a Cd-free LED light source that could be 
used as an HPS replacement. However the data compares lamps with CRI above 90, 
whereas as HPS lamps with much lower CRI values are also used, for example in street 
lighting (see for example Ex. 4b and Ex. 4c of Annex III of the RoHS Directive). 

6.5.3 

Conclusions 

Article 5(1)(a) provides that an exemption can be justified if at least one of the following 
criteria is fulfilled:  

 

 
 

their elimination or substitution via design changes or materials and 
components which do not require any of the materials or substances listed in 
Annex II is scientifically or technically impracticable;  
the reliability of substitutes is not ensured;  
the total negative environmental, health and consumer safety impacts 
caused by substitution are likely to outweigh the total environmental, health 
and consumer safety benefits thereof.  

Study to Assess RoHS Exemptions  

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It can be understood that quantum dots can be used to produce light sources with a 
warmer light and higher colour rendering properties. The stakeholders argue that such 
light sources have fewer losses in the spectral non-visible infra-red range, thus also 
resulting in products with lower waste heat. The consultants can follow that in some 
areas of application where warmer light and high colour rendering is required, that such 
technologies may provide energy savings in comparison to other available light sources. 
However it is currently not possible to clarify relevant areas of application at a level, 
which would allow comparing QD light source performance to the performance of other 
light sources. The current information may suggest that an exemption could be 
restricted to light sources above a certain CRI, however in order to establish if such an 
exemption would be justified, it would further be necessary to substantiate information 
and data as to the following aspects in order to allow a comprehensive comparison and a 
conclusive evaluation: 

  The area of application in terms of the purpose of the light source and its 

required light parameters (i.e., CRI, CCT, R9, light output, etc.);  

  The characteristics of the light sources being compared (as relevant to 

package comparison/lamp comparison / luminaire comparison) and the 
parameters of relevance thereto (for example, number of LED packages, bill 
of materials, data on heat sink components, etc.). Here the detail of a 
comparison would depend on the products being compared; 

  The characteristic performance parameters of the light sources being 

compared (luminous efficiency, input power, etc.). 

At present, it is understood that a general exemption is requested for the use of Cd in 
quantum dot application in solid state lighting. However it is clear from the available 
information that in some areas the unique properties of Cd QD LED light sources are not 
relevant to the scope of an exemption. For example, energy consumption benefits can 
be understood to be significant above certain CRI and R9 values and at lower CCT values 
(warmer light temperatures). However below such values there would be negligible or 
possibly no benefits and the exemption would not be justified as other light sources can 
achieve the same function without the use of Cd.   

At present it is also not possible to demarcate a more narrow scope where the 
exemption would be justified. Though some parameters have been clarified to be of 
relevance to such a demarcation (CRI, CCT, R9, etc.), it has not yet been possible to 
determine the values at which benefits can be expected. It also seems probably that 
such values would be application sensitive and would therefor only justify exemptions 
for the use of the technology in certain application areas, which are yet to be defined. 
Finally, it is apparent that there may be substance alternatives, which may prove to be 
substitutes for Cd within the quantum dot application. For such cases, the performance 
of the two technologies needs to be compared either on an LED package basis (should 
this be possible from available data) or on a product/application sensitive basis (where 
package data cannot be obtained in the public realm). 

Once a comparison can be performed in relation to the aspects above, it shall be 
possible to determine for various applications if an exemption is justified in line with the 

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5(1)(a) criteria – if substitutes are available that provide a comparable reliability and for 
which environmental and health benefits would not outweigh those of Cd QD LED light 
sources. 

7.0  Recommendation 

The information and data made available shows that CdSe QDs can be used in displays to 
provide higher colour gamut and to reduce energy consumption. Though there are 
displays using CdSe with lower performance in this respect, “swap” comparisons of QD 
films allow concluding that differences would be related to the performance of other 
display components, whereas when these are held constant, CdSe show better 
performance in comparison with InP QDs. In this sense an exemption would be 
understood to be justified due to benefits that CdSe QDs could provide in terms of 
energy efficiency and in some cases also in relation to colour gamut, at least where InP 
QD displays are assumed to be the only appropriate alternative. In parallel, it is apparent 
that the display market is a highly dynamic one, and other technologies have been 
observed showing similar colour gamut. For these technologies energy efficiency 
performance was not specified and it cannot be concluded if their performance would 
be comparable or not. As such products are understood to be relatively new 
technologies in terms of their use in products on the market, the consultants 
recommend providing a short termed exemption so that changes in products on the 
market can be observed.  

In parallel, it is beyond the scientifically based assessment mandate of the exemption 
evaluation to conclude whether the use of a RoHS restricted substance to enable a 
certain function or property is an acceptable cost therefor. Though in some cases 
functions may be related to environmental, health or consumer safety benefits, this only 
seems to be the case for products of categories 8 and 9. There is a wide variety of 
displays used in other categories (televisions, telecommunications and displays of other 
EEE) and the fact that a certain function could be added does not allow concluding 
whether this function would be critical for other consumers. Though this aspect is 
beyond the scope of this review, in the consultants opinion it is an aspect to be 
considered as part of the decision process on deciding whether to grant the requested 
exemption or not and what its duration should be.  

At present it is not recommended to grant an exemption for the use of Cd QDs in lighting 
applications. Though this technology may have environmental benefits in certain 
application areas, the available information shows that an exemption would not be 
justified in all areas of lighting applications. In contrast, the information currently 
available does not allow demarcating applications of relevance for an exemption with a 
more narrow scope. Nor can the possible extent of relevant environmental benefits, 
such as energy saving, be understood for such applications so that it is not yet possible 
to understand in what areas an exemption would be justified and in what areas it would 
not. Nonetheless, where manufacturers can show that Cd QD light sources for specific 

Study to Assess RoHS Exemptions  

87 

 
 
application areas have benefits over other light source alternatives, it would still be 
possible to submit a request for exemption in the future. 

Exemption 39 

Duration* 

Cadmium selenide in downshifting cadmium based semiconductor 
nanocrystal quantum dots for use in display lighting applications 
(< 0.2 μg Cd per mm2 of display screen area) 

An exemption should 
be granted for three 
years 

7.1 

References Exemption Request 9 

3M (2013a)  

3M DMSD (2015)  

3M DMSD (2016a) 

ALA (2016)  

Baillie Gifford (2015) 

Baron et al. (2014)  

3M Optical Systems Division original exemption request document concerning 
exemption request 5; available under 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_IX/Request_20
13-5/3M_QDEF_Exemption_Dossier.pdf, retrieved on 05 June 2013   

3M Display Materials & Systems Division, Re: 1st Questionnaire Regarding CdQD 
Exemptions, submitted 26.10.2015, available under:   
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
D_Exs_3M_DMSD_QDEF_RoHS_Excemption_1st_Questionnaire_PACK_10_2015
2610_.pdf 

3M  Display  Materials  &  Systems  Division,  Re:    Pack  10  Stakeholder  Comment 
Questionnaire  Regarding  CdQD  Exemptions,  submitted  7.1.2016,  available 
under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
uantum_Dot_Evaluation/3M_DMSD_Stakeholder_Contribution_PACK_10__002
_.pdf 

The  American  Lighting  Association,  Contribution  to  consultation  on  the 
Revaluation  of  Two  Requests  Related  to  Cd-QD  Technologies,  submitted 
8.1.2016, available under:   
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
uantum_Dot_Evaluation/the_American_Lighting_Association_ALA_Cadmium_Le
tter.pdf  

Baillie Gifford & Co, Response to 2015 Consultation 3: Joint Revaluation of Two 
Requests  for  Exemption,  First  reviewed  in  2013-2014,  Related  to  Cadmium 
Quantum Dot Applications, submitted 22.12.2015, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
uantum_Dot_Evaluation/Letter_to_Ms_Baron_Related_to_Cadmium_Quantum
_Dot_Applications_21_Dec_20....pdf 

Baron, Y.; Blepp, M.; Gensch, C.-O.; Deubzer, O.; in collaboration with Hogg, D., 
Assistance to the Commission on technological, socio-economic and cost-benefit 
assessment  related  to  exemptions  from  the  substance  restrictions  in  electrical 
and  electronic  equipment  (RoHS  Directive)  -  Pack  4,  Eunomia  Research  & 
Consulting Ltd. in cooperation with Oeko-Institut e.V. & Fraunhofer IZM; 2014, 
Commissioned  by:  European  Commission,  DG  Environment,  Brussels,  available 
under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_IX/20140422_R
oHS2_Evaluation_Ex_Requests_2013-1-5_final.pdf 

88 

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BASF (2016)  

BIS (2016)  

Buchert et al. (2012) 

ChemSec (2015)  

Close Brothers (2015) 

CREE (2016)  

Dow (2016)  

EC (2015a)  

BASF, RoHS Exemption Request 2013-2 QD Vision, submitted 8.1.2016, available 
under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
uantum_Dot_Evaluation/BASF_QD_Vision_Oekoinstitut.pdf 

Department for Business and Innovation Skills, Contribution to Stakeholder 
Consultation 2015-3 – Joint Revaluation of Two Requests for Exemption, First 
Reviewed in 2013-2014, Related to Cadmium Quantum Dot Applications, 
submitted 7.1.2016, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
uantum_Dot_Evaluation/Department_for_Business_Innovation_Skills_Contribut
ion__Exemption_39_8_Jan_2016.pdf 

Buchert, M.; Bleher, D.; Manhart, A.; Pingel, D.; Oeko-Institute, Recycling critical 
raw  materials  from  waste  electronic  equipment  [Recycling  kritischer  Rohstoffe 
aus  Elektronikaltgeräten]  Commissioned  by:  North  Rhine-Westphalian  State 
Agency 
for  Nature  Conservation,  Environmental  Affairs  and  Consumer 
Protection (LANUV), Recklinghausen, available under:  
http://www.oeko.de/oekodoc/1375/2012-010-en.pdf  

The International Chemical Secretariat, Response to 2015 Consultation 3: Joint 
Revaluation of Two Requests for Exemption, First Reviewed in 2013-2014, 
Related to Cadmium Quantum Dot Applications, submitted 21.12.2015, 
available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
uantum_Dot_Evaluation/151221_PC_RoHS_Cadmium_Chemsec_FINAL.pdf 

The Close Brothers Asset Management, Response to 2015 Consultation 3: Joint 
Revaluation of Two Requests for Exemption, First reviewed in 2013-2014, 
Related to Cadmium Quantum Dot Applications, submitted 21.12.2015, 
available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
uantum_Dot_Evaluation/21122015_OKO_INSTITUT_LETTER_FROM_RFM__2_.p
df  

CREE Inc., Santa Barbara Technology Center, Consultation Questionnaire 
Regarding Cd Exemptions, submitted 11.1.2016, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
uantum_Dot_Evaluation/CREE__RoHS_Cd_exemption_consultation.pdf 

DOW Europe GmbH, Contribution to Stakeholder Consultation, submitted 
8.1.2016, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
uantum_Dot_Evaluation/DOW_Europe_GmbH_Letter_RoHS_Jan_2016_final_.p
df 

European Commission, COMMISSION DELEGATED DIRECTIVE ../.../EU of 
30.1.2015 amending, for the purposes of adapting to technical progress, Annex 
III to Directive 2011/65/EU of the European Parliament and of the Council as 
regards an exemption for cadmium in illumination and display lighting 
applications, referenced as  C(2015) 383 final of 30.1.2015, available under: 
http://ec.europa.eu/transparency/regdoc/rep/3/2015/EN/3-2015-383-EN-F1-
1.PDF 

Study to Assess RoHS Exemptions  

89 

 
 
EC (2015b)  

EEB (2015)  

Engler et al. (2015)  

EP (2015)  

Henderson (2015)  

Hisense (2016)  

InGaN (2016)  

The European Commission, ANNEX to Commission Delegated Directive 
amending, for the purposes of adapting to technical progress, Annex III to 
Directive 2011/65/EU of the European Parliament and of the Council as regards 
an exemption for cadmium in illumination and display lighting applications, 
referenced as C(2015) 383 final of 30.1.2015, available under: 
http://ec.europa.eu/transparency/regdoc/rep/3/2015/EN/3-2015-383-EN-F1-1-
ANNEX-1.PDF   

The European Environmental Bureau, Response to 2015 Consultation 3: Joint 
Revaluation of Two Requests for Exemption, First reviewed in 2013-2014, 
Related to Cadmium Quantum Dot Applications, submitted 7.12.2015, available 
under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
uantum_Dot_Evaluation/20151207_EEB_response_to_RoHS_Exemptions_Evalu
ation.pdf  

Engler, R. E., MacDougall, L. S., Xu, J. B.,  and Willis, J., The Acta Group on behalf 
of  QD  Vision,  Inc.,  L.L.C,  Supplemental  Statement  on  Life  Cycle  Analysis  and 
Comparison  of  Cadmium  (CASRN 7440-43-9,  EC  231-152-8),  Cadmium  Selenide 
(CASRN 1306-24-7, EC 215-148-3) vs. Indium Phosphide (CASRN 22398-80-7, EC 
244-959-5)  for  Colour  Conversion  in  Displays,  26.10.2015,  available  under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
D_Exs__QD_Vision_d_QDV_Supplemental_Life-Cycle_Analysis.pdf 

The European Parliament, European Parliament resolution of 20 May 2015 on 
the Commission delegated directive of 30 January 2015 amending, for the 
purposes of adapting to technical progress, Annex III to Directive 2011/65/EU of 
the European Parliament and of the Council as regards an exemption for 
cadmium in illumination and display lighting applications (C(2015)00383 – 
2015/2542(DEA)), available under: 
http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//TEXT+TA+P8-
TA-2015-0205+0+DOC+XML+V0//EN&language=EN 

Henderson Global Investors Ltd, Response to 2015 Consultation 3: Joint 
Revaluation of Two Requests for Exemption, First reviewed in 2013-2014, 
Related to Cadmium Quantum Dot Applications, submitted 16.12.2015, 
available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
uantum_Dot_Evaluation/Hwnderson_Globa_Investors201512231029.pdf 

Hinsense, About Quantum Dot Enhancement Films, submitted 8.1.2016, 
available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
uantum_Dot_Evaluation/Hisense_Contribution.pdf   

InGaN Research Ltd, Response to 2015 Consultation 3: Joint Revaluation of Two 
Requests for Exemption, First reviewed in 2013-2014, Related to Cadmium 
Quantum Dot Applications, submitted 8.1.2016, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
uantum_Dot_Evaluation/InGaN_Research_Ltd_Response_to_RoHS_exemption_
of_QDs_-_7-1-16.pdf  

Goodman (2015)  

EdifERA, Socio-economic assessment for Cd QD displays, submitted to 
stakeholder consultation by 3M DMSD on 7.1.2016, available under: 

90 

17/05/2016 

 
 
KEMI (2015)  

LEU (2015)  

Lumileds (2015a)  

Lumileds (2016a)  

http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
uantum_Dot_Evaluation/3M_socio_economic_reportf.pdf  

The Swedish Chemicals Agency, Contribution to Stakeholder Consultation 2015-
3  -  Joint Revaluation of Two Requests for Exemption, First Reviewed in 2013-
2014, Related to Cadmium Quantum Dot Applications submitted 21.12.2015, 
submitted 21.12.2015, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
uantum_Dot_Evaluation/SE_CA_Answer_to_SC_RoHS_2015_3_Joint_Revaluatio
n_of_cadmium_in_quantum_dots.pdf  

LightingEurope, Support Letter on Exemption 39, submitted 9.12.2015, available 
under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
uantum_Dot_Evaluation/LE_support_letter_RoHS_Ex_39_Cadmium_20151209.
pdf  

Lumileds Germany GmbH, Input for stakeholder consultation for RoHS 
exemption requests 2013-2 and 2013-5, submitted 14.12.2016, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
uantum_Dot_Evaluation/20151214_Oeko_Institut_consultation.pdf  

Lumileds Germany GmbH, Comparative life cycle assessment of LED lamps 
based on cadmium containing quantum dots and conventional phosphors 
prepared for Lumileds, submitted 8.1.2016, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
uantum_Dot_Evaluation/Lumileds_20160108_LCA_Results_final.pdf 

Lumileds (2016b)  

Lumileds Germany GmbH, Answers to 1st Clarification Questionnaire Regarding 
CdQD Exemptions, submitted 18.4.2016 

Nanoco-Dow (2013a) 

Nanoco (2015a)  

Nanoco (2016a)  

Nanoco (2016b)  

Nanosys (2016)  

Nanoco Technologies and DOW, Contribution made concerning Ex. Re. 2013-2 – 
answers to RoHS Consultation Questionnaire, submitted by Nanoco 
Technologies Limited & Dow Electronic Materials on 06.11.2013, available 
under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_IX/Request_20
13-2/20131106_Nonoco_Dow_Contribution_Ex_2013-
2_Response_to_RoHS_Questionnaire.pdf    

Nanoco Technologies, Nanoco Response to 1st Questionnaire Regarding CdQD 
Exemptions, submitted 28.10.2015, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
D_Exs_Nanoco_Response_to_RoHS_Questions_27_Oct_2015.pdf 

Nanoco Technologies, Page Response to Public Consultation Questionnaire 
Regarding Cadmium QD Exemptions, submitted 8.1.2016, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
uantum_Dot_Evaluation/Nanoco_Technologies_RoHS_response_final_2016010
8.pdf  

Nanoco Technologies, Response to Additional Questionnaire (2nd Round) 
Regarding Cadmium QD Exemptions, submitted 20.4.2016 

Nanosys, Input for stakeholder consultation for RoHS exemption requests 2013-
2 and 2013-5, submitted 8.1.2016, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q

Study to Assess RoHS Exemptions  

91 

 
 
NDF (2015)  

Prakash el al. (2016)  

QD Vision (2013a)  

QD Vision (2015a)  

QD Vision (2015b)  

QD Vision (2016a) 

uantum_Dot_Evaluation/Nanosys_Input_for_Stakeholder_Consultation_-
_CdSe_vs_InP__Cd-
free__Quantum_Dot_Performance_Measurement_and_Analysis.pdf 

NDF Special Light Products BV, NDF CW adj 1514 - Cadmium Quantum Dot 
applications, submitted 3.12.2015, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
uantum_Dot_Evaluation/NDF_CW_adj_1514_-
_Cadmium_Quantum_Dot_applications.pdf 

Prakash, S.; Antony, F.; Dehoust, G.; Gsell, M.; Köhler, A. R.; Schleicher, T.; in 
collaboration with Stamminger, R.; Oeko-Institut e.V. in cooperation with 
Friedrich-Wilhelm-Universität Bonn, Einfluss der Nutzungsdauer von Produkten 
auf ihre Umweltwirkung: Schaffung einer Informationsgrundlage und 
Entwicklung von Strategien gegen „Obsoleszenz" [Influence of the service life of 
products in terms of their environmental impact: Establishing an information 
base and developing policies against "obsolescence"] Commissioned by: German 
Federal Environment Agency (UBA), Dessau (FKZ UFOPLAN 3713 32 315), pg. 
149, available under: 
https://www.umweltbundesamt.de/sites/default/files/medien/378/publikation
en/texte_11_2016_einfluss_der_nutzungsdauer_von_produkten_obsoleszenz.p
df  

QD VISION, QD Vision original exemption request document concerning 
exemption request 2; available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_IX/Request_20
13-2/20132301_NON-
CONFIDENTIAL_Request_for_renewal_of_exemption_39.pdf, retrieved on 
12.12.2013   

QD VISION, QD VISION Responses to Question by Oeko-Institut Regarding 
Exemption 39.b, submitted 28.10.2015, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
D_Exs__QD_Vision_a_QD_Vision_Response_to_Oeko-
Institut_Regarding_Exemption_39.B.pdf  

QD VISION, Benchmarking of QD Televisions, submitted 28.10.2015, available 
under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
D_Exs__QD_Vision_e_QD_Television_Benchmarking.pdf 

QD VISION, QD Vision Response to Nanoco’s Oeko Submission on Exemption 
39.B, submitted 8.1.2016, available under: 
http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_10/Cd_Q
uantum_Dot_Evaluation/QD_Vision_Response_to_Nanoco_Submission_FINAL_
010816.pdf  

QD Vision (2016c)  

QD VISION, QD VISION Response to Oeko Institut Questions (2nd Round) on 
Rohs Exemption 39b, submitted 19.4.2016 

QD Vision (2016d) 

QD VISION, QD VISION Response to Oeko Institut Questions (3rd Round) on Rohs 
Exemption 39b, submitted 21.4.2016 

92 

17/05/2016 

 
 
 
APPENDICES 

Study to Assess RoHS Exemptions  

93 

 
 
 
A.1.0  Appendix 1: Relevant REACH 

Regulation Entries 

Relevant annexes and processes related to the REACH Regulation have been cross-
checked to clarify: 

 

In what cases granting an exemption could “weaken the environmental and 
health protection afforded by Regulation (EC) No 1907/2006” (Article 5(1)(a), 
pg.1) 

  Where processes related to the REACH regulation should be followed to 

understand where such cases may become relevant in the future; 

The last consolidated version has been consulted in this respect, published on 2 February 
2016. Compiled information in this respect has been included, with short clarifications 
where relevant, in the following tables:  

Table A. 1 lists those substances appearing in Annex XIV, subject to Authorisation, which 
are relevant to the RoHS substances dealt with in the requests evaluated in this project. 
As can be seen, at present, exemptions have not been granted for the use of these 
substances. 

Table A. 1: Relevant Entries from Annex XIV: The List of Substances 
Subject to Authorization 

Designation of the substance, of the group of 
substances, or of the mixture 

Transitional arrangements 

Latest application 
date ( 1 ) 

Sunset date ( 2 ) 

Exempted (categories of) 
uses 

4. Bis(2-ethylhexyl) phthalate (DEHP) 
EC No: 204-211-0 
CAS No: 117-81-7 

21 August 2013 

21 February 2015 

5. Benzyl butyl phthalate (BBP) 
EC No: 201-622-7 
CAS No: 85-68-7 

21 August 2013 

21 February 2015 

6. Dibutyl phthalate (DBP) 
EC No: 201-557-4 
CAS No: 84-74-2 

7. Diisobutyl phthalate (DIBP) 
EC No: 201-553-2 
CAS No: 84-69-5 
10. Lead chromate  

21 August 2013 

21 February 2015 

21 August 2013 

21 February 2015 

21 November 2013  

21 May 2015 

- 

Uses in the immediate 
packaging of medicinal 
products covered under 
Regulation (EC) No 
726/2004, Directive 
2001/82/EC, and/or 
Directive 2001/83/EC. 
Uses in the immediate 
packaging of medicinal 
products covered under 
Regulation (EC) No 
726/2004, Directive 
2001/82/EC, and/or 
Directive 2001/83/EC. 
Uses in the immediate 
packaging of medicinal 
products covered under 
Regulation (EC) No 
726/2004, Directive 
2001/82/EC, and/or 
Directive 2001/83/EC. 

Study to Assess RoHS Exemptions  

94 

 
 
 
Designation of the substance, of the group of 
substances, or of the mixture 

Transitional arrangements 

Latest application 
date ( 1 ) 

Sunset date ( 2 ) 

Exempted (categories of) 
uses 

EC No: 231-846-0  
CAS No: 7758-97-6 
11. Lead sulfochromate yellow  
(C.I. Pigment Yellow 34)  
EC No: 215-693-7  
CAS No: 1344-37-2 
12. Lead chromate molybdate sulphate red  
(C.I. Pigment Red 104)  
EC No: 235-759-9  
CAS No: 12656-85-8 
16. Chromium trioxide 
EC No: 215-607-8 
CAS No: 1333-82-0 
17. Acids generated from chromium trioxide 
and their oligomers 
Group containing: 
Chromic acid 
EC No: 231-801-5 
CAS No: 7738-94-5 
Dichromic acid 
EC No: 236-881-5 
CAS No: 13530-68-2 
Oligomers of chromic acid and dichromic 
acid 
EC No: not yet assigned 
CAS No: not yet assigned 
18. Sodium dichromate 
EC No: 234-190-3 
CAS No: 7789-12-0 
10588-01-9 
19. Potassium dichromate 
EC No: 231-906-6 
CAS No: 7778-50-9 
20. Ammonium dichromate 
EC No: 232-143-1 
CAS No: 7789-09-5 
21. Potassium chromate 
EC No: 232-140-5 
CAS No: 7789-00-6 
22. Sodium chromate 
EC No: 231-889-5 
CAS No: 7775-11-3 
28. Dichromium tris(-chromate) 
EC No: 246-356-2  
CAS No: 24613-89-6 
29. Strontium chromate 
EC No: 232-142-6 CAS 
 No: 7789-06-2 
30. Potassium 
hydroxyoctaoxodizincatedichromate  
EC No: 234-329-8  
CAS No: 11103-86-9 
31. Pentazinc chromate octahydroxide 
 EC No: 256-418-0  
CAS No: 49663-84-5 

21 November 2013  

21 May 2015 

21 November 2013  

21 May 2015 

21 March 2016 

21 September 2017 

- 

- 

- 

21 March 2016 

21 September 2017 

- 

- 

- 

- 

21 March 2016 

21 September 2017 

21 March 2016 

21 September 2017 

21 March 2016 

21 September 2017 

21 March 2016 

21 September 2017 

21 March 2016 

21 September 2017 

22. July 2017 

22 January 2019 

22 July 2017 

22 January 2019 

22 July 2017 

22 January 2019 

22 July 2017 

22 January 2019 

For the substances currently restricted according to RoHS Annex II: cadmium, hexavalent 
chromium, lead, mercury, polybrominated biphenyls and polybrominated diphenyl 
ethers and their compounds, we have found that some relevant entries are listed in 
Annex XVII of the REACH Regulation. The conditions of restriction are presented in Table 

17/05/2016 

95 

 
 
 
 
 
 
 
 
A. 2 below. Additionally, some amendments have been decided upon, and are still to be 
included in the concise version. These may be seen in Table A. 3. 

Table A. 2: Conditions of Restriction in REACH Annex XVII for RoHS 
Substances and Compounds  

Designation of the substance, of the 
group of substances or of the mixture 

Conditions of restriction 

8. Polybromobiphenyls; 
Polybrominatedbiphenyls (PBB) CAS 
No 59536-65-1 

1. Shall not be used in textile articles, such as garments, undergarments and linen, 
intended to come into contact with the skin.  
2. Articles not complying with paragraph 1 shall not be placed on the market. 

16. Lead carbonates:  
(a) Neutral anhydrous carbonate 
(PbCO 3 )  
CAS No 598-63-0  
EC No 209-943-4  
(b) Trilead-bis(carbonate)-dihydroxide 
2Pb CO 3 -Pb(OH) 2  
CAS No 1319-46-6  
EC No 215-290-6 

17. Lead sulphates:  
(a) PbSO 4  
CAS No 7446-14-2  
EC No 231-198-9  
(b) Pb x SO 4  
CAS No 15739-80-7  
EC No 239-831-0 

18. Mercury compounds  

18a. Mercury  
CAS No 7439-97-6 
EC No 231-106-7 

Shall not be placed on the market, or used, as substances or in mixtures, where the 
substance or mixture is intended for use as paint. 
However, Member States may, in accordance with the provisions of International Labour 
Organization (ILO) Convention 13, permit the use on their territory of the substance or 
mixture for the restoration and maintenance of works of art and historic buildings and 
their interiors, as well as the placing on the market for such use. Where a Member State 
makes use of this derogation, it shall inform the Commission thereof. 

Shall not be placed on the market, or used, as substances or in mixtures, where the 
substance or mixture is intended for use as paint. 
However, Member States may, in accordance with the provisions of International Labour 
Organization (ILO) Convention 13, permit the use on their territory of the substance or 
mixture for the restoration and maintenance of works of art and historic buildings and 
their interiors, as well as the placing on the market for such use. Where a Member State 
makes use of this derogation, it shall inform the Commission thereof. 

Shall not be placed on the market, or used, as substances or in mixtures where the 
substance or mixture is intended for use:  
(a) to prevent the fouling by micro-organisms, plants or animals of: 

— 
— 

— 

the hulls of boats,  
cages, floats, nets and any other appliances or equipment used for fish or 
shellfish farming,  
any totally or partly submerged appliances or equipment;  

(b) in the preservation of wood;  
(c) in the impregnation of heavy-duty industrial textiles and yarn intended for their 
manufacture;  
(d) in the treatment of industrial waters, irrespective of their use. 

1.  Shall not be placed on the market: 

(a) 
(b) 

in fever thermometers; 
in other measuring devices intended for sale to the general public (such as 
manometers, barometers, sphygmomanometers, thermometers other than 
fever thermometers). 

2.  The restriction in paragraph 1 shall not apply to measuring devices that were in use in 
the Community before 3 April 2009. However Member States may restrict or prohibit the 
placing on the market of such measuring devices. 
3.  The restriction in paragraph 1(b) shall not apply to: 

(a)  measuring devices more than 50 years old on 3 October    2007; 
(b)  barometers (except barometers within point (a)) until 3 October 2009. 

5.  The following mercury-containing measuring devices intended for industrial and 
professional uses shall not be placed on the market after 10 April 2014: 

(a)  barometers; 
(b)  hygrometers; 
(c)  manometers; 
(d) 
(e) 

sphygmomanometers; 
strain gauges to be used with plethysmographs; 

Study to Assess RoHS Exemptions  

96 

 
 
(f) 
(g) 

tensiometers; 
thermometers and other non-electrical thermometric applications. 

The restriction shall also apply to measuring devices under points (a) to (g) which are 
placed on the market empty if intended to be filled with mercury. 
6.  The restriction in paragraph 5 shall not apply to: 

(a) 

sphygmomanometers to be used: 
i. 
ii. 

in epidemiological studies which are ongoing on 10 October 2012; 
as reference standards in clinical validation studies of mercury-free 
sphygmomanometers; 

(b) 

thermometers exclusively intended to perform tests according to standards 
that require the use of mercury thermometers until 10 October 2017; 

(c)  mercury triple point cells which are used for the calibration of platinum 

resistance thermometers. 

7.  The following mercury-using measuring devices intended for professional and 
industrial uses shall not be placed on the market after 10 April 2014: 

(a)  mercury pycnometers; 
(b)  mercury metering devices for determination of the softening point. 

8.  The restrictions in paragraphs 5 and 7 shall not apply to: 

(a)  measuring devices more than 50 years old on 3 October 2007; 
(b)  measuring devices which are to be displayed in public exhibitions for cultural 

and historical purposes. 

For the purpose of this entry, the codes and chapters indicated in square brackets are the 
codes and chapters of the tariff and statistical nomenclature of Common Customs Tariff as 
established by Council Regulation (EEC) No 2658/87 (1). 
1.  Shall not be used in mixtures and articles produced from the following synthetic 
organic polymers (hereafter referred to as plastic material): 
— polymers or copolymers of vinyl chloride (PVC) [3904 10] [3904 21] 
— polyurethane (PUR) [3909 50] 
— low-density polyethylene (LDPE), with the exception of low-density polyethylene used 
for the production of coloured masterbatch [3901 10] 
— cellulose acetate (CA) [3912 11] 
— cellulose acetate butyrate (CAB) [3912 11] 
— epoxy resins [3907 30] 
— melamine-formaldehyde (MF) resins [3909 20] 
— urea-formaldehyde (UF) resins [3909 10] 
— unsaturated polyesters (UP) [3907 91] 
— polyethylene terephthalate (PET) [3907 60] 
— polybutylene terephthalate (PBT) 
— transparent/general-purpose polystyrene [3903 11] 
— acrylonitrile methylmethacrylate (AMMA) 
— cross-linked polyethylene (VPE) 
— high-impact polystyrene 
— polypropylene (PP) [3902 10] 
Mixtures and articles produced from plastic material as listed above shall not be placed on 
the market if the concentration of cadmium (expressed as Cd metal) is equal to or greater 
than 0,01 % by weight of the plastic material. 
By way of derogation, the second subparagraph shall not apply to articles placed on the 
market before 10 December 2011. 
The first and second subparagraphs apply without prejudice to Council Directive 
94/62/EC (13) and acts adopted on its basis. 
By 19 November 2012, in accordance with Article 69, the Commission shall ask the 
European Chemicals Agency to prepare a dossier conforming to the requirements of 
Annex XV in order to assess whether the use of cadmium and its compounds in plastic 
material, other than that listed in subparagraph 1, should be restricted. 
2.  Shall not be used in paints [3208] [3209]. 
For paints with a zinc content exceeding 10 % by weight of the paint, the concentration of 
cadmium (expressed as Cd metal) shall not be equal to or greater than 0,1 % by weight. 
Painted articles shall not be placed on the market if the concentration of cadmium 
(expressed as Cd metal) is equal to or greater than 0,1 % by weight of the paint on the 

23. Cadmium and its compounds 
CAS No 7440-43-9  
EC No 231-152-8  

17/05/2016 

97 

 
 
painted article. 
3.  By way of derogation, paragraphs 1 and 2 shall not apply to articles coloured with 
mixtures containing cadmium for safety reasons. 
4.  By way of derogation, paragraph 1, second subparagraph shall not apply to: 
— mixtures produced from PVC waste, hereinafter referred to as ‘recovered PVC’, 
— mixtures and articles containing recovered PVC if their concentration of cadmium 
(expressed as Cd metal) does not exceed 0,1 % by weight of the plastic material in the 
following rigid PVC applications: 
—  
(a)  profiles and rigid sheets for building applications; 
(b)  doors, windows, shutters, walls, blinds, fences, and roof gutters; 
(c)  decks and terraces; 
(d)  cable ducts; 
(e)  pipes for non-drinking water if the recovered PVC is used in the middle layer of a 
multilayer pipe and is entirely covered with a layer of newly produced PVC in compliance 
with paragraph 1 above. 
Suppliers shall ensure, before the placing on the market of mixtures and articles 
containing recovered PVC for the first time, that these are visibly, legibly and indelibly 
marked as follows: ‘Contains recovered PVC’ or with the following pictogram: 

In accordance with Article 69 of this Regulation, the derogation granted in paragraph 4 
will be reviewed, in particular with a view to reducing the limit value for cadmium and to 
reassess the derogation for the applications listed in points (a) to (e), by 31 December 
2017. 
5.  For the purpose of this entry, ‘cadmium plating’ means any deposit or coating of 
metallic cadmium on a metallic surface. 
Shall not be used for cadmium plating metallic articles or components of the articles used 
in the following sectors/applications: 
(a)  equipment and machinery for: 
— food production [8210] [8417 20] [8419 81] [8421 11] [8421 22] [8422] [8435] [8437] 
[8438] [8476 11] 
— agriculture [8419 31] [8424 81] [8432] [8433] [8434] [8436] 
— cooling and freezing [8418] 
— printing and book-binding [8440] [8442] [8443] 
(b)  equipment and machinery for the production of: 
— household goods [7321] [8421 12] [8450] [8509] [8516] 
— furniture [8465] [8466] [9401] [9402] [9403] [9404] 
— sanitary ware [7324] 
— central heating and air conditioning plant [7322] [8403] [8404] [8415] 
In any case, whatever their use or intended final purpose, the placing on the market of 
cadmium-plated articles or components of such articles used in the sectors/applications 
listed in points (a) and (b) above and of articles manufactured in the sectors listed in point 
(b) above is prohibited. 
6.  The provisions referred to in paragraph 5 shall also be applicable to cadmium-plated 
articles or components of such articles when used in the sectors/applications listed in 
points (a) and (b) below and to articles manufactured in the sectors listed in (b) below: 
(a)  equipment and machinery for the production of: 
— paper and board [8419 32] [8439] [8441] textiles and clothing [8444] [8445] [8447] 
[8448] [8449] [8451] [8452] 
(b)  equipment and machinery for the production of: 
— industrial handling equipment and machinery [8425] [8426] [8427] [8428] [8429] 
[8430] [8431] 

Study to Assess RoHS Exemptions  

98 

 
 
 
— road and agricultural vehicles [chapter 87] 
— rolling stock [chapter 86] 
— vessels [chapter 89] 
7.  However, the restrictions in paragraphs 5 and 6 shall not apply to: 
— articles and components of the articles used in the aeronautical, aerospace, mining, 
offshore and nuclear sectors whose applications require high safety standards and in 
safety devices in road and agricultural vehicles, rolling stock and vessels, 
— electrical contacts in any sector of use, where that is necessary to ensure the reliability 
required of the apparatus on which they are installed. 
8.  Shall not be used in brazing fillers in concentration equal to or greater than 0,01 % by 
weight. 
Brazing fillers shall not be placed on the market if the concentration of cadmium 
(expressed as Cd metal) is equal to or greater than 0,01 % by weight. 
For the purpose of this paragraph brazing shall mean a joining technique using alloys and 
undertaken at temperatures above 450 °C. 
9.  By way of derogation, paragraph 8 shall not apply to brazing fillers used in defence and 
aerospace applications and to brazing fillers used for safety reasons. 
10.  Shall not be used or placed on the market if the concentration is equal to or greater 
than 0,01 % by weight of the metal in: 
(i)  metal beads and other metal components for jewellery making; 
(ii)  metal parts of jewellery and imitation jewellery articles and hair accessories, including: 
— bracelets, necklaces and rings, 
— piercing jewellery, 
— wrist-watches and wrist-wear, 
— brooches and cufflinks. 
11.  By way of derogation, paragraph 10 shall not apply to articles placed on the market 
before 10 December 2011 and jewellery more than 50 years old on 10 December 2011. 

Without prejudice to the other parts of this Annex the following shall apply to entries 28 
to 30: 
1.  Shall not be placed on the market, or used, 
— as substances, 
— as constituents of other substances, or, 
— in mixtures, 
for supply to the general public when the individual concentration in the substance or 
mixture is equal to or greater than: 
— either the relevant specific concentration limit specified in Part 3 of Annex VI to 
Regulation (EC) No 1272/2008, or,  
— the relevant generic concentration limit specified in Part 3 of Annex I of Regulation (EC) 
No 1272/2008.   
Without prejudice to the implementation of other Community provisions relating to the 
classification, packaging and labelling of substances and mixtures, suppliers shall ensure 
before the placing on the market that the packaging of such substances and mixtures is 
marked visibly, legibly and indelibly as follows: 
2.  By way of derogation, paragraph 1 shall not apply to: 

(a)  medicinal or veterinary products as defined by Directive 2001/82/EC and 

Directive 2001/83/EC;  

(b)  cosmetic products as defined by Directive 76/768/EEC;  
(c) 

the following fuels and oil products: 
— motor fuels which are covered by Directive 98/70/EC, 
— mineral oil products intended for use as fuel in mobile or fixed combustion 
plants,  
— fuels sold in closed systems (e.g. liquid gas bottles); 

(d)  artists’ paints covered by Regulation (EC) No 1272/2008;  
(e) 

the substances listed in Appendix 11, column 1, for the applications or uses 
listed in Appendix 11, column 2. Where a date is specified in column 2 of 
Appendix 11, the derogation shall apply until the said date.   

28.  
Substances which appear in Part 3 of 
Annex VI to Regulation (EC) No 
1272/2008 classified as carcinogen 
category 1A or 1B (Table 3.1) or 
carcinogen category 1 or 2 (Table 3.2) 
and listed as follows: 
— Carcinogen category 1A (Table 
3.1)/carcinogen category 1 (Table 3.2) 
listed in Appendix 1 
— Carcinogen category 1B (Table 
3.1)/carcinogen category 2 (Table 3.2) 
listed in Appendix 2:  
Chromium (VI) trioxide 
Zinc chromates including zinc 
potassium chromate 
Nickel chromate 
Nickel dichromate 
Potassium dichromate 
Ammonium dichromate 
Sodium dichromate 
Chromyl dichloride; chromic 
oxychloride 
Potassium chromate  
Calcium chromate  
Strontium chromate  
Chromium (VI) compounds, with the 
exception of barium chromate and of 
compounds specified elsewhere in 
Annex VI to Regulation (EC) No 
1272/2008 
Chromium III chromate; chromic 
chromate  

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Sodium chromate 
Cadmium oxide 
Cadmium chloride 
Cadmium fluoride 
Cadmium Sulphate 
Cadmium sulphide 
Cadmium (pyrophoric)  
Chromium (VI) trioxide 
Lead Chromate 
Lead hydrogen arsenate  
Silicic acid, lead nickel salt Lead 
sulfochromate yellow; C.I. Pigment 
Yellow 34; 
Lead chromate molybdate sulfate red; 
C.I. Pigment Red 104; 

29.  

Substances which appear in Part 3 of 
Annex VI to Regulation (EC) No 
1272/2008 classified as germ cell 
mutagen category 1A or 1B (Table 3.1) 
or mutagen category 1 or 2 (Table 3.2) 
and listed as follows: 
— Mutagen category 1A (Table 
3.1)/mutagen category 1 (Table 3.2) 
listed in Appendix 3 
— Mutagen category 1B (Table 
3.1)/mutagen category 2 (Table 3.2) 
listed in Appendix 4 
Cadmium chloride 
Cadmium fluoride 
Cadmium Sulphate 
Chromium (VI) trioxide  
Potassium dichromate  
Ammonium dichromate 
Sodium dichromate  
Chromyl dichloride; chromic 
oxychloride  
Potassium chromate  
Sodium chromate  

30. 
Substances which appear in Part 3 of 
Annex VI to Regulation (EC) No 
1272/2008 classified as toxic to 
reproduction category 1A or 1B (Table 
3.1) or toxic to reproduction category 
1 or 2 (Table 3.2) and listed as follows: 
— Reproductive toxicant category 1A 
adverse effects on sexual function and 
fertility or on development (Table 3.1) 
or reproductive toxicant category 1 
with R60 (May impair fertility) or R61 
(May cause harm to the unborn child) 
(Table 3.2) listed in Appendix 5 

— Reproductive toxicant category 1B 
adverse effects on sexual function and 
fertility or on development (Table 3.1) 
or reproductive toxicant category 2 
with R60 (May impair fertility) or R61 
(May cause harm to the unborn child) 
(Table 3.2) listed in Appendix 6:  

Study to Assess RoHS Exemptions  

100 

 
 
 
Bis(2-ethylhexyl) phthalate; di-(2-
ethylhexyl) phthalate; DEHP 
Benzyl butyl phthalate; BBP 
Dibutyl phthalate; DBP  
Diisobutyl phthalate 
Cadmium chloride 
Cadmium fluoride 
Cadmium Sulphate 
Potassium dichromate  
Ammonium dichromate 
Sodium dichromate  
Sodium chromate  
Nickel dichromate 
Lead compounds with the exception of 
those specified elsewhere in this 
Annex  
Lead hydrogen arsenate 
Lead acetate  
Lead alkyls  
Lead azide 
Lead Chromate  
Lead di(acetate)  
Lead hydrogen arsenate 
Lead 2,4,6-trinitroresorcinoxide, lead 
styphnate  
Lead(II) methane- sulphonate  
Trilead bis- (orthophosphate) 
Lead hexa-fluorosilicate  
Mercury 
Silicic acid, lead nickel salt 

47. Chromium VI compounds 

1. Cement and cement-containing mixtures shall not be placed on the market, or used, if 
they contain, when hydrated, more than 2 mg/kg (0,0002 %) soluble chromium VI of the 
total dry weight of the cement. 
2.  If reducing agents are used, then without prejudice to the application of other 
Community provisions on the classification, packaging and labelling of substances and 
mixtures, suppliers shall ensure before the placing on the market that the packaging of 
cement or cement-containing mixtures is visibly, legibly and indelibly marked with 
information on the packing date, as well as on the storage conditions and the storage 
period appropriate to maintaining the activity of the reducing agent and to keeping the 
content of soluble chromium VI below the limit indicated in paragraph 1. 
3.  By way of derogation, paragraphs 1 and 2 shall not apply to the placing on the market 
for, and use in, controlled closed and totally automated processes in which cement and 
cement-containing mixtures are handled solely by machines and in which there is no 
possibility of contact with the skin. 
4. The standard adopted by the European Committee for Standardization (CEN) for testing 
the water-soluble chromium (VI) content of cement and cement-containing mixtures shall 
be used as the test method for demonstrating conformity with paragraph 1. 
5. Leather articles coming into contact with the skin shall not be placed on the market 
where they contain chromium VI in concentrations equal to or greater than 3 mg/kg 
(0,0003 % by weight) of the total dry weight of the leather.  
6. Articles containing leather parts coming into contact with the skin shall not be placed 
on the market where any of those leather parts contains chromium VI in concentrations 
equal to or greater than 3 mg/kg (0,0003 % by weight) of the total dry weight of that 
leather part.  
7. Paragraphs 5 and 6 shall not apply to the placing on the market of second-hand articles 
which were in end-use in the Union before 1 May 2015.   

51. The following phthalates (or other 
CAS and EC numbers covering the 
substance): 
(a)  Bis (2-ethylhexyl) phthalate (DEHP) 
CAS No 117-81-7 
EC No 204-211-0 

1. Shall not be used as substances or in mixtures, in concentrations greater than 0,1 % by 
weight of the plasticised material, in toys and childcare articles.  
2.  Toys and childcare articles containing these phthalates in a concentration greater than 
0,1 % by weight of the plasticised material shall not be placed on the market.  
4.  For the purpose of this entry ‘childcare article’ shall mean any product intended to 
facilitate sleep, relaxation, hygiene, the feeding of children or sucking on the part of 

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101 

 
 
children. 

(b)  Dibutyl phthalate (DBP) 
CAS No 84-74-2 
EC No 201-557-4 
(c)  Benzyl butyl phthalate (BBP) 
CAS No 85-68-7 
EC No 201-622-7 

63. Lead and its compounds 
CAS No 7439-92-1 EC No 231-100-4  

1. Shall not be placed on the market or used in any individual part of jewellery articles if 
the concentration of lead (expressed as metal) in such a part is equal to or greater than 
0,05 % by weight.  
2. For the purposes of paragraph 1: 
 (i) ‘jewellery articles’ shall include jewellery and imitation jewellery articles and hair 
accessories, including:  

(a) bracelets, necklaces and rings;  
(b) piercing jewellery; 
(c) wrist watches and wrist-wear;  
(d) brooches and cufflinks;  

(ii) ‘any individual part’ shall include the materials from which the jewellery is made, as 
well as the individual components of the jewellery articles.  
3. Paragraph 1 shall also apply to individual parts when placed on the market or used for 
jewellery-making.  
4. By way of derogation, paragraph 1 shall not apply to: 
(a) crystal glass as defined in Annex I (categories 1, 2, 3 and 4) to Council Directive 
69/493/EEC (*);  
(b) internal components of watch timepieces inaccessible to consumers;  
(c) non-synthetic or reconstructed precious and semiprecious stones (CN code 7103, as 
established by Regulation (EEC) No 2658/87), unless they have been treated with lead or 
its compounds or mixtures containing these substances; 
(d) enamels, defined as vitrifiable mixtures resulting from the fusion, vitrification or 
sintering of minerals melted at a temperature of at least 500 °C. 
5. By way of derogation, paragraph 1 shall not apply to jewellery articles placed on the 
market for the first time before 9 October 2013 and jewellery articles produced before 10 
December 1961. 
6. By 9 October 2017, the Commission shall re-evaluate paragraphs 1 to 5 of this entry in 
the light of new scientific information, including the availability of alternatives and the 
migration of lead from the articles referred to in paragraph 1 and, if appropriate, modify 
this entry accordingly. 
7. Shall not be placed on the market or used in articles supplied to the general public, if 
the concentration of lead (expressed as metal) in those articles or accessible parts thereof 
is equal to or greater than 0,05 % by weight, and those articles or accessible parts thereof 
may, during normal or reasonably foreseeable conditions of use, be placed in the mouth 
by children. That limit shall not apply where it can be demonstrated that the rate of lead 
release from such an article or any such accessible part of an article, whether coated or 
uncoated, does not exceed 0,05 μg/cm 2 per hour (equivalent to 0,05 μg/g/h), and, for 
coated articles, that the coating is sufficient to ensure that this release rate is not 
exceeded for a period of at least two years of normal or reasonably foreseeable 
conditions of use of the article. For the purposes of this paragraph, it is considered that an 
article or accessible part of an article may be placed in the mouth by children if it is 
smaller than 5 cm in one dimension or has a detachable or protruding part of that size. 
8. By way of derogation, paragraph 7 shall not apply to: 
(a) jewellery articles covered by paragraph 1; 
(b) crystal glass as defined in Annex I (categories 1, 2, 3 and 4) to Directive 69/493/ EEC;  
(c) non-synthetic or reconstructed precious and semi-precious stones (CN code 7103 as 
established by Regulation (EEC) No 2658/ 87) unless they have been treated with lead or 
its compounds or mixtures containing these substances;  
(d) enamels, defined as vitrifiable mixtures resulting from the fusion, vitrification or 
sintering of mineral melted at a temperature of at least 500 ° C;  
(e) keys and locks, including padlocks;  
(f) musical instruments;  
(g) articles and parts of articles comprising brass alloys, if the concentration of lead 
(expressed as metal) in the brass alloy does not exceed 0,5 % by weight;  

Study to Assess RoHS Exemptions  

102 

 
 
(h) the tips of writing instruments  

(i) religious articles;  

(j) portable zinc-carbon batteries and button cell batteries;  

(k) articles within the scope of: (i) Directive 94/62/EC; (ii) Regulation (EC) No 1935/2004; 
(iii) Directive 2009/48/EC of the European Parliament and of the Council (**); (iv) Directive 
2011/65/EU of the European Parliament and of the Council (***)  

9. By 1 July 2019, the Commission shall re-evaluate paragraphs 7 and 8(e), (f), (i) and (j) of 
this entry in the light of new scientific information, including the availability of alternatives 
and the migration of lead from the articles referred to in paragraph 7, including the 
requirement on coating integrity, and, if appropriate, modify this entry accordingly.  

10. By way of derogation paragraph 7 shall not apply to articles placed on the market for 
the first time before 1 June 2016.  

(*) OJ L 326, 29.12.1969, p. 36.  

(**) Directive 2009/48/EC of the European Parliament and of the Council of 18 June 2009 
on the safety of toys (OJ L 170, 30.6.2009, p. 1).  
(***) Directive 2011/65/EU of the European Parliament and of the Council of 8 June 2011 
on the restriction of the use of certain hazardous substances in electrical and e l e c t r o n 
i c e q u i p m e n t ( O J L 1 7 4 , 1.7.2011, p. 88). 

Table A. 3: Summary of Relevant Amendments to Annexes Not Updated in 
the Last Concise Version of the REACH Regulation  

Designation of the substance, of the group 
of substances, or of the mixture 

Conditions of restriction 

Amended 
Annex 

Amendment 
date 

Addition of Entry 62 concerning: 

(a) Phenylmercury acetate  

EC No: 200-532-5  

CAS No: 62-38-4  

(b) Phenylmercury propionate  

EC No: 203-094-3  

CAS No: 103-27-5  

(c) Phenylmercury 2-ethylhexanoate  

EC No: 236-326-7  

CAS No: 13302-00-6  

(d) Phenylmercury octanoate  

EC No: -  

CAS No: 13864-38-5  

(e) Phenylmercury neodecanoate  

EC No: 247-783-7  

CAS No: 26545-49-3 

1. Shall not be manufactured, placed 
on the market or used as substances or 
in mixtures after 10 October 2017 if 
the concentration of mercury in the 
mixtures is equal to or greater than 
0,01% by weight.  

2. Articles or any parts thereof 
containing one or more of these 
substances shall not be placed on the 
market after 10 October 2017 if the 
concentration of mercury in the 
articles or any part thereof is equal to 
or greater than 0,01% by weight.’ 

Annex XVII, 
entry 62 

20 Sep 2012 

As of 28 September 2015, the REACH Regulation Candidate list includes those substances 
relevant for RoHS listed in Table A. 4 (i.e. proceedings concerning the addition of these 
substances to the Authorisation list (Annex XIV) have begun and shall be followed by the 

17/05/2016 

103 

 
 
evaluation team to determine possible discrepancies with future requests of exemption 
from RoHS (new exemptions, renewals and revocations))143: 

Table A. 4: Summary of Relevant Substances Currently on the REACH 
Candidate List 

Substance Name 

EC No. 

CAS No. 

Cadmium fluoride 

232-222-0 

7790-79-6 

Cadmium sulphate 

233-331-6 

10124-36-4 
31119-53-6 

Cadmium chloride  

233-296-7  

10108-64-2  

Cadmium sulphide  

215-147-8 

1306-23-6 

Lead di(acetate)  

206-104-4 

301-04-2 

Cadmium  

231-152-8 

7440-43-9 

Cadmium oxide  

215-146-2 

1306-19-0 

232-382-1 
237-486-0 
233-245-9 
234-363-3 
235-727-4 
215-267-0 

8012-00-8 
13814-96-5 
10099-74-8 
11120-22-2 
12626-81-2 
1317-36-8 

Date of 
Inclusion 

17 
December 
2014 

17 
December 
2014 

16 June 
2014 

Reason for inclusion 

Carcinogenic (Article 57 a); Mutagenic 
(Article 57 b); Toxic for reproduction 
(Article 57 c); Equivalent level of 
concern having probable serious 
effects to human health (Article 57 f) 
Carcinogenic (Article 57 a); Mutagenic 
(Article 57 b); Toxic for reproduction 
(Article 57 c); Equivalent level of 
concern having probable serious 
effects to human health (Article 57 f) 

Carcinogenic (Article 57a); 

20 Jun 2013 

16 Dec 2013 

16 Dec 2013 

Carcinogenic (Article 57a);  
Equivalent level of concern having 
probable serious effects to human 
health (Article 57 f)  
Toxic for reproduction (Article 57 c); 
Carcinogenic (Article 57a); Equivalent 
level of concern having probable 
serious effects to human health 
(Article 57 f) 
Carcinogenic (Article 57a); Equivalent 
level of concern having probable 
serious effects to human health 
(Article 57 f) 
Toxic for reproduction (Article 57 c) 
19 Dec 2012 
Toxic for reproduction (Article 57 c) 
19 Dec 2012 
Toxic for reproduction (Article 57 c)  
19 Dec 2012 
Toxic for reproduction (Article 57 c) 
19 Dec 2012 
19 Dec 2012 
Toxic for reproduction (Article 57 c)  
19 Dec 2012   Toxic for reproduction (Article 57 c) 

20 Jun 2013 

Pyrochlore, antimony lead yellow 
Lead bis(tetrafluoroborate) 
Lead dinitrate  
Silicic acid, lead salt  
Lead titanium zirconium oxide  
Lead monoxide (lead oxide)  
Silicic acid (H2Si2O5), barium salt (1:1), 
lead-doped  
[with lead (Pb) content above the 
applicable generic concentration limit for 
’toxicity for reproduction’ Repr. 1A (CLP) 
or category 1 (DSD); the substance is a 
member of the group entry of lead 
compounds, with index number 082-001-
00-6 in Regulation (EC) No 1272/2008]  
Trilead bis(carbonate)dihydroxide  
Lead oxide sulfate  
Lead titanium trioxide  
Acetic acid, lead salt, basic  
[Phthalato(2-)]dioxotrilead  
Tetralead trioxide sulphate  
Dioxobis(stearato)trilead  
Tetraethyllead  
Pentalead tetraoxide sulphate  
Trilead dioxide phosphonate  

272-271-5 

68784-75-8 

19 Dec 2012 

Toxic for reproduction (Article 57 c)  

215-290-6 
234-853-7 
235-038-9 
257-175-3 
273-688-5 
235-380-9 
235-702-8 
201-075-4 
235-067-7 
235-252-2 

1319-46-6 
12036-76-9 
12060-00-3 
51404-69-4 
69011-06-9 
12202-17-4 
12578-12-0 
78-00-2 
12065-90-6 
12141-20-7 

19 Dec 2012 
19 Dec 2012 
19 Dec 2012 
19 Dec 2012 
19 Dec 2012 
19 Dec 2012 
19 Dec 2012 
19 Dec 2012 
19 Dec 2012 
19 Dec 2012 

Toxic for reproduction (Article 57 c) 
Toxic for reproduction (Article 57 c)  
Toxic for reproduction (Article 57 c)  
Toxic for reproduction (Article 57 c)  
Toxic for reproduction (Article 57 c) 
Toxic for reproduction (Article 57 c) 
Toxic for reproduction (Article 57 c)  
Toxic for reproduction (Article 57 c)  
Toxic for reproduction (Article 57 c) 
Toxic for reproduction (Article 57 c) 

143 Updated according to http://echa.europa.eu/web/guest/candidate-list-table 

Study to Assess RoHS Exemptions  

104 

 
 
 
                                                       
 
Substance Name 

EC No. 

CAS No. 

Orange lead (lead tetroxide)  
Sulfurous acid, lead salt, dibasic  
Lead cyanamidate  
Lead(II) bis(methanesulfonate)  
Lead diazide, Lead azide  
Lead dipicrate  
Dichromium tris(chromate)  
Pentazinc chromate octahydroxide  
Potassium 
hydroxyoctaoxodizincatedichromate  
Lead styphnate  

Strontium chromate  
Acids generated from chromium trioxide 
and their oligomers. Names of the acids 
and their oligomers: Chromic acid, 
Dichromic acid, Oligomers of chromic acid 
and dichromic acid.  

215-235-6 
263-467-1 
244-073-9 
401-750-5 
236-542-1 
229-335-2 
246-356-2 
256-418-0 

1314-41-6 
62229-08-7 
20837-86-9 
17570-76-2 
13424-46-9 
6477-64-1 
24613-89-6 
49663-84-5 

Date of 
Inclusion 
19 Dec 2012 
19 Dec 2012 
19 Dec 2012 
18 Jun 2012 
19 Dec 2011 
19 Dec 2011 
19 Dec 2011 
19 Dec 2011 

Reason for inclusion 

Toxic for reproduction (Article 57 c)  
Toxic for reproduction (Article 57 c)  
Toxic for reproduction (Article 57 c) 
Toxic for reproduction (Article 57 c)  
Toxic for reproduction (article 57 c),  
Toxic for reproduction (article 57 c)  
Carcinogenic (article 57 a) 
Carcinogenic (article 57 a) 

234-329-8 

11103-86-9 

19 Dec 2011 

Carcinogenic (article 57 a) 

239-290-0 

15245-44-0 

19 Dec 2011 

Toxic for reproduction (article 57 c)  
Carcinogenic and toxic for 
reproduction (articles 57 a and 57 c) 
Carcinogenic (article 57a) 

231-801-5, 
236-881-5 

7738-94-5, 
13530-68-2 

15 Dec 2010 

Carcinogenic (article 57a)  

Trilead diarsenate  

222-979-5 

3687-31-8 

19 Dec 2011 

232-142-6 

7789-06-2  

20 Jun 2011 

Chromium trioxide  

215-607-8 

1333-82-0 

15 Dec 2010 

Potassium dichromate  

231-906-6 

7778-50-9 

18 Jun 2010 

Ammonium dichromate  

232-143-1 

7789-09-5 

18 Jun 2010 

Sodium chromate  

231-889-5 

7775-11-3 

18 Jun 2010 

Potassium chromate  

232-140-5 

7789-00-6 

18 Jun 2010 

Lead sulfochromate yellow (C.I. Pigment 
Yellow 34)  
Lead chromate molybdate sulphate red 
(C.I. Pigment Red 104)  

215-693-7 

1344-37-2 

13 Jan 2010 

235-759-9 

12656-85-8 

13 Jan 2010 

Lead chromate  

231-846-0 

7758-97-6 

13 Jan 2010 

Lead hydrogen arsenate  

232-064-2 

7784-40-9 

28 Oct 2008 

Sodium dichromate  

234-190-3 

7789-12-0, 
10588-01-9 

28 Oct 2008 

Carcinogenic and mutagenic (articles 
57 a and 57 b)  
Carcinogenic, mutagenic and toxic for 
reproduction (articles 57 a, 57 b and 
57 c) 
Carcinogenic, mutagenic and toxic for 
reproducetion (articles 57 a, 57 b and 
57 c) 
Carcinogenic, mutagenic and toxic for 
reproduction (articles 57 a, 57 b and 
57 c) 
Carcinogenic and mutagenic (articles 
57 a and 57 b). 
Carcinogenic and toxic for 
reproduction (articles 57 a and 57 c))  
Carcinogenic and toxic for 
reproduction (articles 57 a and 57 c) 
Carcinogenic and toxic for 
reproduction (articles 57 a and 57 c)  
Carcinogenic and toxic for 
reproduction (articles 57 a and 57 c) 
Carcinogenic, mutagenic and toxic for 
reproduction (articles 57a, 57b and 
57c) 

Additionally, Member States can register intentions to propose restrictions or to classify 
substances as SVHC. The first step is to announce such an intention. Once the respective 
dossier is submitted, it is reviewed and it is decided if the restriction or authorisation 
process should be further pursued or if the intention should be withdrawn.  

As at the time of writing (Fall 2015), it cannot yet be foreseen how these procedures will 
conclude. It is thus not yet possible to determine if the protection afforded by REACH 
Regulation would in these cases consequently be weakened by approving the exemption 
requests dealt with in this report. For this reason, the implications of these decisions 
have not been considered in the review of the exemption requests dealt with in this 

17/05/2016 

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report. However for the sake of future reviews, the latest authorisation or restriction 
process results shall be followed and carefully considered where relevant.144 

As for registries of intentions to identify substances as SVHC, as of 28 September 2015, 
Sweden has submitted intentions regarding the classification of cadmium fluoride and 
cadmium sulphate as CMR, intending to submit dossiers in August 2014.None of the 
current registries of intentions to propose restrictions apply to RoHs regulated 
substances.145 

As for prior registrations of intention, dossiers have been submitted for the substances 
listed in Table A. 5. 

Table A. 5: Summary of Substances for which a Dossier has been 
submitted, following the initial registration of intention 

Restriction / 
SVHC 
Classification 

Substance Name 

Submission 
Date 

Submitted by 

Comments 

17 Jan 2014 

Sweden 

Artist paints 

Cadmium  
and its compounds  

Cadmium  
and its compounds  

17 Oct 2013 

ECHA 

Restriction 

Lead and lead compounds  

18 Jan 2013 

Sweden 

Chromium VI 

20 Jan 2012  Denmark 

Phenylmercuric octanoate;  
Phenylmercury propionate; 
Phenylmercury 2-ethylhexanoate; 
Phenylmercury acetate; 
Phenylmercury 
Mercury in measuring devices 
Lead and its compounds in jewellery 
Cadmium chloride 
Cadmium sulphide 
Lead di(acetate) 
Cadmium 

ECHA 
France 
Sweden 
Sweden 

15 Jun 2010 
15 Apr 2010 
03 Feb 2014 
05 Aug 2013 
05 Aug 2013  Netherlands 
04 Feb 2013 

Sweden 

SVHC 
Classification 

Cadmium oxide 

04 Feb 2013 

Sweden 

Trilead dioxide Phosphonate; 
Lead Monoxide (Lead Oxide); 

30 Aug 2012 

ECHA 

15 Jun 2010  Norway 

Mercury compounds 

Amendment of the current 
restriction (entry 23) on use of 
paints with TARIC codes [3208] 
& [3209] containing cadmium 
and cadmium compounds to 
include placing on the market 
of such paints and a 
concentration limit. 
Placing on the market of 
consumer articles containing 
Lead and its compounds 
Placing on the market of 
leather articles containing 
Chromium VI 

Mercury compounds 
Substances containing lead 
CMR; other; 
CMR; other; 
CMR 
CMR; other;  
Substances containing Cd 
CMR; other;  
Substances Containing Cd 
CMR; substances Containing 
Lead 

144 European Chemicals Agency (ECHA), Registry of intentions to propose restrictions: 
http://echa.europa.eu/registry-of-current-restriction-proposal-intentions/-
/substance/1402/search/+/term (28.09.2015) 
145 ECHA website, accessed 28.09.2015: http://echa.europa.eu/web/guest/addressing-chemicals-of-
concern/registry-of-intentions  

Study to Assess RoHS Exemptions  

106 

 
 
                                                       
 
Trilead bis(carbonate)dihydroxide;  
Lead Dinitrate; 
Lead Oxide Sulphate; 
Acetic acid, lead salt, basic; 
Dioxobis(stearato)trilead; 
Lead bis(tetrafluoroborate); 
Tetraethyllead; 
Pentalead tetraoxide sulphate; 
Lead cyanamidate; 
Lead titanium trioxide; 
Silicic acid (H2Si2O5), barium salt (1:1), 
lead-doped; 
Silicic acid, lead salt; 
Sulfurous acid, lead salt, dibasic; 
Tetralead trioxide sulphate; 
[Phthalato(2-)]dioxotrilead; 
Orange lead (lead tetroxide); 
Fatty acids, C16-18, lead salts; 
Lead titanium zirconium oxide 
Lead(II) bis(methanesulfonate) 
Lead styphnate;  
Lead diazide; Lead azide; 
Lead dipicrate 
Trilead diarsenate 

30 Jan 2012  Netherlands 

CMR; Amides 

01 Aug 2011 

ECHA 

CMR; Substances containing 
lead 

CMR; Arsenic compounds 
CMR; Substances containing 
chromate 

Strontium Chromate 

24 Jan 2011 

France 

Acids generated from chromium 
trioxide and their oligomers: Chromic 
acid; 
Dichromic acid; 
Oligomers of chromic acid and 
dichromic acid 

27 Aug 2010  Germany 

CMR; Substances containing 
chromate 

Chromium Trioxide 

02 Aug 2010  Germany 

Sodium chromate; 
Potassium chromate; 
Potassium Dichromate 
Lead chromate molybdate sulfate red 
(C.I. Pigment Red 104);  
Lead sulfochromate yellow (C.I. 
Pigment Yellow 34) 

10 Feb 2010 

France 

03 Aug 2009 

France 

Lead Chromate 

03 Aug 2009 

France 

Lead hydrogen arsenate 

27 Jun 2008  Norway 

Sodium dichromate 

26 Jun 2008 

France 

CMR; Substances containing 
chromate 

CMR; Substances containing 
chromate 

CMR; substances Containing 
Lead 

CMR; Substances containing 
chromate 
CMR; Arsenic compounds 
CMR; Substances containing 
chromate 

Concerning the above mentioned processes, as at present, it cannot be foreseen if, or 
when, new restrictions or identification as SVHC might be implemented as a result of this 
proposal; its implications have not been considered in the review of the exemption 
requests dealt with in this report. In future reviews, however, on-going research into 
restriction and identification as SVHC processes and the results of on-going proceedings 
shall be followed and carefully considered where relevant. 

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107 

 
 
 
 
A.2.0  Appendix 2: Nanoco Information as to 
QD Alternatives for HPS Horticultural 
Lighting and for High Pressure Sodium 
Lighting 

Source: Nanoco (2016b), Nanoco Technologies, Response to Additional Questionnaire 
(2nd Round) Regarding Cadmium QD Exemptions, submitted 20.4.2016 

A.2.1  High Pressure Sodium Lighting 

Nanoco explains that cadmium-free QD lighting is highly suitable as an alternative to 
high pressure sodium (HPS) lamps. HPS lamps typically have a high energy consumption 
(150 – 1,000 W), with some energy being wasted as heat. They also have short lifetimes. 
Cadmium-free QD lighting encompasses the energy efficiency properties and improved 
performance lifetimes of LED lighting, but can also be used to achieve a CCT closer to 
that of natural daylight than standard white LEDs, which tend to emit bluish light. HPS 
lighting systems are often designed to either maximize on CRI or on efficiency as 
demonstrated by the Philips Master Colour HPS series146 which provide lamps at CCT 
6600 K, CRI Ra 92, and LES 76 lm W-1. This is due to the lack of tunability in the red region 
of the spectrum for HPS technology as only specific impurities can be used to adjust the 
emission colour, resulting in compromises in either the efficiency or colour rendering 
ability of a light source. QD emission spectra, however, are defined by the size and size 
distribution of the nanocrystals in the ensemble used for light colour conversion.147 This 
allows for a high level of emission tunability using QDs with different species capable of 
producing emission across various parts of the visible spectrum (Figure A - 1), and also 
allows for narrow width of spectral emission by controlling the nanocrystal size 
distribution. This in turn means that QDs can be tuned to specifically hit the wavelengths 
required by light sources at differing CCT values to maximize both CRI Ra and R9 values. In 
addition controlling the emission to be of narrow width also means that excess 
unnecessary wavelengths will not be emitted in the less eye sensitive red region of the 

146 Referenced in Nanoco (2016b) as Wesco, “Philips CDM250S50/V/O/4K-ALTO.” [Online]. Available: 
https://buy.wesco.com/Standard-Light-Bulbs/PHILIPS/Metal-Halide-Light-Bulb-250-W-ED-18/CDM250S50-
V-O-4K-ALTO/p/78667713093-1. [Accessed: 18-Apr-2016].   
147Referenced in Nanoco (2016b) as  X. Yang, D. Zhao, K. S. Leck, S. T. Tan, Y. X. Tang, J. Zhao, H. V. Demir, 
and X. W. Sun, “Full Visible Range Covering InP/ZnS Nanocrystals with High Photometric Performance and 
Their Application to White Quantum Dot Light-Emitting Diodes,” Adv. Mater., vol. 24, no. 30, pp. 4180–
4185, 2012   

Study to Assess RoHS Exemptions  

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spectrum, maximizing the potential LES values for sources tuned to maximize CRI. Using 
such technology, Nanoco Lighting has managed to produce commercial luminaires with 
excellent colour rendering properties and competitive LES values, such as in the 
luminaire spectrum shown in Figure A - 2.  

Figure A - 1: Emission Tunability of a Selection of Visible Light Emitting 
QDs Overlaid with a Spectral Power Distribution of a Commercially 
Available 6500 K White LED (Blue Line). Red Bars Indicate QDs Containing 
Toxic Cadmium 

Source: Nanoco (2016b) 

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Figure A - 2: Measured Emission Spectrum of a Nanoco 
6500KCCT300X300CDWT Model Luminaire (Left) with Accompanying 
Measured Characteristics (Right). 

Source: Nanoco (2016b) 

A.2.2  Horticultural Lighting 

“Horticultural lighting is used to supplement or replace natural sunlight during the plant 
growing process, typically in an indoor environments such as greenhouses or indoor 
vertical farms. Horticultural lighting is used to stimulate different molecular species 
within the plant of interest to encourage more efficient photosynthesis or adjust the 
plants circadian rhythm during the growing process. Each molecular species within the 
plant will have a slightly different light absorption profile as detailed in Figure A - 3. 

Study to Assess RoHS Exemptions  

110 

 
 
Figure A - 3: Typical Absorption Profiles of Different Molecular Species 
Found in plants. Chlorophyll A and B along with Carotenoid are 
Responsible for Energy Absorption to Enable Photosynthesis, while 
Phytochrome PR and FPR are Responsible for Circadian Rhythm Control 

Source: Nanoco (2016b) 

HPS lamps are currently commonly used for horticultural lighting due to their high 
energy efficiency. Their emission profile however does not coincide very well with the 
absorption profile of the targeted molecular species to encourage plant growth (see 
Figure A - 4), resulting in wasted energy at non-required wavelengths in the system. Also 
studies have shown that different plant species require specific ratios of red and blue 
excitation light for optimized growth148 and, due to the lack of tunability in HPS lighting 
systems, this cannot be accommodated for. 

148 Quoted as P. Davis, “Lighting : The review,” UHDB, 2014   

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111 

 
 
 
                                                       
 
Figure A - 4: Typical Absorption Profiles of Chlorophyll A and B Overlaid 
with the Typical Emission Spectrum of a Commercial HPS Grow Light. 

Source: Nanoco (2016b) 

The current industry trend is moving away from HPS towards mixed LED lighting, where 
a combination of red and blue LEDs are used in a light fixture to generate the required 
emission at the required light colour ratios. These units solve the issue of wasted 
unnecessary light, allowing for more efficient growing systems. A further advantage of 
LED lighting is that it emits little energy as heat, allowing the lighting to be placed much 
closer to the growing plants. One downfall with mixed LED lighting, however, is the 
colour mixing of the independent red and blue sources before it hits the plant bed. This 
is particularly important in areas such as propagation in vertical farming applications, 
where full and even illumination of a seedbed is required over short distances in order to 
save space. Also, due to the very narrow emission width of the LEDs and limitations in 
available red wavelengths, only specific molecules can be targeted in plant, with little 
flexibility to stimulate different molecules or multiple molecules at the same time. 

QD technology can be used to compliment LED technology in order to combat this issue 
for propagation beds by utilizing the QDs in a remote phosphor format (using QD film 
positioned above the blue LEDs). Remote phosphor allows for an even colour mixing of 
the light of light over a short distance, resulting in a uniform distribution of 
Photosynthetically Active Radiation (PAR) over distances as little as 6 inches (see Figure 
A - 5). Meanwhile the colour tunability of the QDs allows for specific positioning of the 
red peak position to stimulate the desired molecules in the plant for the desired growth 
stage, while the control over the emission width also leads to the ability to target several 
molecules at once using the same light source (see Figure A - 6). 

Study to Assess RoHS Exemptions  

112 

 
 
 
Figure A - 5: Graphic to Show the Principle of Using a Remote QD Phosphor 
Film to Generate Even Light Emission (left), and a Photo Demonstrating the 
Even Emission for a Nanoco Propagator Lamp 

Source: Nanoco (2016b) 

Figure A - 6: Typical Absorption Profiles of Chlorophyll A and B Overlaid 
with the Typical Emission Spectrum of a Commercial Nanoco Propagation 
Lamp, Designed to Target Chlorophyll A and B within a Plant. 

Source: Nanoco (2016b) 

Please note that these are only 2 example areas where we have detailed performance 
data available in the time required for this consultation. A further example is in 
phototherapy applications, where QDs offer a further advantage in that they can be 
incorporated into a flexible film to form a lighting device that can be applied directly to a 
body part to be treated. There are many other potential applications where the tuneable 
emission characteristics of cadmium-free QDs allow for improved lighting performance 
in LED systems that are more energy efficient and flexible than alternative lighting 
technologies.” 

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doi:10.2779/527573