standards and consortium bodies, JEDEC, EIA, IPC, iNEMI, JEITA and IEC. Limit the scope of this new “low-halogen” standard and the respective definition to halogenated materials of concern which are present in the IEC 62474 database. non-ceramic materials in any international consensus standard.” and replace with; “The term “low halogen” is currently defined by international electronics standards organizations although there is no unanimous consensus on the qualitative or quantitative definitions. However there is some discrepancy between the standards as to which term is used and how the terms are defined. To ensure a uniform and consistent understanding of the meaning of “low halogen” throughout the industry, this term needs to be harmonized, and to the extent possible in a horizontal standard, clearly defined as it pertains to many different materials within EEE products. The periodic table identifies the halogen group as containing fluorine, chlorine, bromine, iodine, and astatine; however, this document defines the term “low halogen” as it specifically concerns EEE, halogen compounds and their applications listed within the IEC 62474 Database are the only halogens being considered .” IT03 022-25 te Not only astatine, but also fluorine and iodine should not be considered among the halogens of concern Amend the sentence as follows: The periodic table identifies the halogen group as containing fluorine, chlorine, bromine, iodine and astatine; however, since this document defines the term “low halogen of concern”, as it specifically concerns EEE, astatine is not being considered, likewise fluorine and iodine are not considered: these halogens (particularly fluorine) are widely used in electrotechnology (see Annex A) and with the current status of knowledge they are not of concern for the health and the environment. US6 024 – 26, 28 Introduction Par 3 Te This standard should educate users and permit them to make an informed decision about halogenated materials of concern that does not place unjustified limitations on materials of composition. When implementing determining if a “low halogen” technology is appropriate, this standard shall may be utilized to identify the industry accepted definition within the electrical and electronic industry to help address halogenated materials of concern.
Note: Criteria 3 reporting requirements in the 62474 database are optional, should one choose to define materials or products as Low-Halogen, the requirements including Criteria 3 are considered mandatory. JP5 025 ed POPs regulation is included by the Line 15 Delete Line 16 JP6 026 ge The term “technology” cannot be used here, since it is not an issue. Use “term” instead of “technology”. 028 introduction Te “compliance with any legislation” is not the adequate term; it should be “conformity” (in the same meaning as “declaration of conformity”); on the other hand, “conformance” is not used anywhere in the document. Change the full sentence” into: “Compliance with this standard does not imply conformity with any legislation”. By consistency with section 5.2, “conformity” could also be used at both places, to give the alternate proposal: “Conformitywith this standard does not imply conformity with any legislation”. JP7 028 ge The definition needs to be limited only to products in E&E field. Within ONLY the electrical and electronic industry.
applications, aerospace, chemical processing, building construction, automotive, electronics, energy, environmental protection, and outdoor and technical apparel. Substance restrictions around the world have not identified the use of all fluoropolymers (e.g., PTFE, FEP, PFA) as an area of concern. Halogens are not as a group generally hazardous to the environment, so the inclusion of all halogens in the definition would create unnecessary problems for the electronics industry. Creating a scientifically accurate standard but not dealing with environmental aspects relevant to EEE products is not in the scope of TC 111. NL 12 090-92 4 te It does not make sense to also include Criteria 3 (for information only) substances in the definition of “Low halogen materials”, since the objective of this definition is to include regulated substances that have already been accessed and were demonstrated to pose issues to health and environment when used in EEE Please also note the voting round held during the PT63031 meeting in Wilmington on May 18, 2017 Change second part of the definition to “…and meet the thresholds of all hazardous halogenated Criteria 1+2 substances in the IEC 62474 database” NL 13 090-92 4 te Any limit referred to in this definition shall be based entirely on scientific evidence of an adverse environmental impact in the case such limit is exceeded. The limit of 0,9% lacks scientific evidence of adverse environmental impact, and therefore must not be used in a standard -- or otherwise we will be making legislation instead of a standard. The link with IEC 62474 Criteria 1+2 can be accepted as the substances in these categories are already accessed for their harmful behaviour to environment (or health) Note that IEC 62474 Criteria 3 substances are not determined as concern materials and shall therefore be excluded from the definition Change the definition to: “Materials defined as “Low Halogenated Materials of Concern” shall contain less than 0,9% (by mass) total elemental halogen content (F+Cl+Br+I) and meet the thresholds of all hazardous halogenated Criteria 1+2 substances in the IEC 62474 database” AND add the following sentence : The above definition excludes non-hazardous halogenated substances included in the IEC 62474 database for reporting purposes CN-1 090-93 4 technical There is no scientific basis to to restrict all Delete “contain less than 0,9% (by mass) total
150, 168, 196, 204, 212, 308, 314, 317 etc. proposed restriction level. evidence that the substance poses a risk to the environment or to human health at the proposed restriction level. Each substance needs to be assessed individually for the environmental or human health impacts that can result from its use. 091-92 4 TE The phrase "meet the thresholds" is ambiguous and may cause confusion. Replace "meet the thresholds of all halogenated substances in IEC 62474 database" with "not contain (at or above the applicable threshold level) any halogenated substance that is a declarable substance or included in a declarable substance group on the IEC 62474 declarable substances list (DSL). The applicable threshold for each entry in the IEC 62474 DSL is specified in the ReportingThreshold field. " GB 16 092 4 ed Full stop missing at the end of the sentence. Add the full stop. JP21 092 Section 4 Te [Comments from electronic/electrical product manufacturers and fluoropolymer suppliers point of view] IEC 62474 contains declarable halogenated compounds that are identified to cause concerns to human health and the environment. Use IEC 62474 database as the only source of halogens that are under this low halogen definition. [Proposal from electronic/electrical product manufacturers and fluoropolymer suppliers point of view] Add “, including criteria 1, 2 & 3” after the IEC62474 database. SE 08 092 4 ed Full stop is missing Correct it. JP27 094-164 4 Te [Comments from chemicals and materials suppliers point of view] Concern of halogenated materials can be summarized, if a material may contain regulated restriction substances, or a material may generate hazardous substances in burning behavior. For 1), declaration of halogenated substances [Proposals from chemicals and materials suppliers point of view] Change the specifications as follows: “Materials defined as “halogenated materials of low concern” shall meet the thresholds of all halogenated substances in Criteria 1 of IEC 62474 database, and report as follows: Information on environmental hazards of decomposed substances in burning treatment process of the material used in
JP28 110-116 5 Te [Comments from chemicals and materials suppliers point of view] It’s most useful to develop and prepare a declaration format of halogenated materials in IEC 63031, in order to assist environmental safety communication among various TCs/SCs and supply-chain where they manage different halogenated chemicals or elements with different thresholds in their standards currently. [Proposals from chemicals and materials suppliers point of view] Add a new sub clause in Clause 5 to provide a guidance how to manage a declaration sheet for halogenated materials. Example of the declaration format outline is as follows; A column to declare use of halogenated polymer matrix, and if used, an additional column to declare CAS No. of the chemicals. For remarks, another column can be put to attach information to help environmental safety between production and end-of –life of electrical and electronic products. A column to declare use of non-halogenated polymer matrix. If used, an additional column to declare containment or non-containment either of additives, impurities, or reaction residues of halogens. Then one more column to declare in case of containment of the above halogens, to meet the 0,9 % threshold. For remarks, another column to attach supplements of test reports to confirm halogen contents not exceeding 0.9%. To be linked with both 1) and 2), the final column to declare the materials contain no substance listed in Criteria 1 of IEC 62474. FR 12 111 5.4 1 te All the specifications of clause 4 shall be taken into account. Editorial simplification and better homogeneity with 5.2. Replace the sentence to read “Material declarations providing information on the specifications in clause 4.” 111-112 5.4 Ed/Te This is not a full sentence; to avoid confusion with a definition, consider adding a verb or taking the enclosed suggestion Suggested text (inspired from IEC 63000): “Material declarations provide information on halogenated substance content substances in the material under evaluation. The material declaration content should meet the requirements specified in IEC 62474, subclause 4.2.3 for the halogenated substances.” GB 22 117 5.5 te This clause needs extensive re-writing if it is to be retained. It could be used as a method for Change the text to make it clear that analysis of combustion effluent is not, on its own, a valid
205 A.2.1 Ed Header is useless, since there is no other subsection in A.2 Delete this header NL 28 210-211 A.2.1 ed Sentence does not ‘run’ smoothly Remove “substance groups” from line 210 or add it after non-halogenated substances in line 211 as follows: “The database contains both halogenated substances or substance groups and substances” or “The database contains both halogenated substances or substance groups and substances or substance groups” NL 29 212-214 A.2.1 ed Explanation of Criteria 3 substances is not in place to be added here since similar explanations for Criteria 1 and Criteria 2 are not provided Besides, the message around threshold is not relevant here “[…] which are categorized into Criteria 1 (currently regulated), Criteria 2 (for assessment), and Criteria 3 (for information only) where the reporting threshold value is given based on the lowest applicable regulatory limit or stakeholder requirements in the market of specific applications. Criteria 1 and 2 substances are based on regulatory requirements, and therefore have mandatory declaration, while Criteria 3 substances have non-mandatory declaration as they are based on market specific requirements.” GB 28 215-217 A.2 te “give the foundation for inclusion/exclusion of the halogen in the low halogen definition” is not correct. Also how can categories provide the motivation of limits? Furthemore, TC111 (and therefore this standard) only cover environmental matters. Hence the text “health and” is incorrect as it implies that this standard goes beyond the scope of TC111. Delete lines 215 - 217 NL 30 217 A.2.1 ed No clear to state “based on the health and environmental aspects” “[…]and the motivation of the limits, based on the health and environmental aspects legislation or market requirements.” NL 31 218 A.3 - Title ed What are the additional halogenated substances? Remove the word “additional” from the title: “Materials containing additional halogenated substances to consider environmental aspects”
Annex of SE.doc Proposed Annex B from SE-07 ID SubstanceGroup or SpecificSubstance CAS number Basis Reportable Applications Reporting Threshold Brominated flame retardants (other than PBBs, PBDEs, or HBCDD) *) Criteria 3: For Information Only Printed Wiring Board (PWB) Laminates 0.09 mass% total bromine content in laminate material Brominated flame retardants (other than PBBs, PBDEs, or HBCDD) *) Criteria 3: For Information Only Plastic materials except PWB laminates 0.1 mass% of bromine in plastic materials Cobalt dichloride 7646-79-9 Criteria 1: Currently Regulated All 0.1 mass% of article Fluorinated Greenhouse Gases (PFC, SF6, HFC) *) Criteria 1: Currently Regulated All Intentionally Added in product Hexabromocyclododecane (HBCDD) and all major diastereoisomers identified: Alpha-hexabromocyclododecane Gamma-hexabromocyclododecane *) Criteria 1: Currently Regulated All Intentionally added or 0.1 mass% of article Ozone Depleting Substances (CFC, Halon, HBFC, HCFC & others) *) Criteria 1: Currently Regulated All Intentionally Added in product Perchlorates *) Criteria 1: Currently Regulated All 6 x 10 ^-7 mass% of battery or product part Polybrominated Biphenyls (PBBs) *) Criteria 1: Currently Regulated All 0.1 mass% in homogenous material Polybrominated Diphenylethers (PBDEs) *) Criteria 1: Currently All 0.1 mass% in homogenous material
Regulated Polychlorinated Biphenyls (PCBs) and specific substitutes *) Criteria 1: Currently Regulated All Intentionally added in product Polychlorinated Terphenyls (PCTs) *) Criteria 1: Currently Regulated All 0.005 mass% in material Polychlorinated Naphthalenes (PCNs) *) Criteria 1: Currently Regulated All Intentionally added in product Alkanes, C10-13, chloro (Short Chain Chlorinated Paraffins) *) Criteria 1: Currently Regulated All Intentionally added or 0.1 mass% of article Tris(2-chloroethyl) phosphate 115-96-8 Criteria 1: Currently Regulated All 0.1 mass% of article Chlorinated Flame Retardants (CFR) *) Criteria 3: For Information Only Plastic materials except PWB laminates 0.1 mass% chlorine in plastic materials Chlorinated Flame Retardants (CFR) *) Criteria 3: For Information Only Printed Wiring Board (PWB) Laminates 0.09 mass% total chlorine content in laminate material Bis(pentabromophenyl) ether (decabromodiphenyl ether) (DecaBDE) 1163-19-5 Criteria 1: Currently Regulated All 0.1 mass% of article Pyrochlore, antimony lead yellow 8012-00-8 Criteria 1: Currently Regulated All 0.1 mass% of article Dibutyltin dichloride (DBTC) 683-18-1 Criteria 1: Currently Regulated All 0.1 mass% of article Pentadecafluorooctanoic acid (PFOA) 335-67-1 Criteria 1: Currently Regulated All 0.1 mass% of article Ammonium pentadecafluorooctanoate (APFO) 3825-26-1 Criteria 1: Currently Regulated All 0.1 mass% of article