New EU RoHS Project to Review Restricted Substance List and Exemptions

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February 13, 2018Kirsten WallerstedtBlog
On 9 February 2018, the Oeko-Institut announced the launch of a "Study to support the review of the list of restricted substances and to assess a new exemption request under RoHS 2." This study is categorized as RoHS Pack 15, and includes the assessment of seven substances for possible addition to Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment (EEE) (RoHS or RoHS 2).
RoHS requires that electrical and electronic equipment (EEE) which is placed on the EU market does not contain the substances listed in Annex II of the Directive above a set limit. Some exemptions are provided in the other annexes.
The Role of Oeko-Institut with RoHS
The Oeko-Institut provides assistance to the European Commission (EC) on "technological, socio-economic and cost-benefit assessment related to exemptions from the substance restrictions in electrical and electronic equipment (RoHS Directive)." The EC relies upon the Oeko Institut's evaluations and recommendations in order to decide how and whether to allow certain exemptions from the RoHS requirements. Oeko evaluates exemption requests in groups that it calls "packs."
Pack 15 consists of two parts:
Part 1: Substance restriction review
The review of the list of restricted substances will include three tasks:
  1. Update the existing methodology to identify and assess substances for possible restriction;
  2. Assess substances with a view to their possible future restriction; and
  3. Determine the quantitative usage data for substances used in EEE.
Seven substances have been identified for assessment as part of Pack 15:
  1. Diantimony trioxide (flame retardant);
  2. Tetrabromobisphenol A (TBBP-A, flame retardant);
  3. Indium phosphide (InP);
  4. Medium chain chlorinated paraffins (MCCPs) - Alkanes, 14-17, chloro;
  5. Beryllium and its compounds;
  6. Nickel sulphate and nickel sulfamate; and
  7. Cobalt dichloride and cobalt sulphate.
Part 2: Exemption evaluation
For the exemption evaluation part of Pack 15, Oeko-Institut will provide technical and scientific support for evaluating the exemption methodology and the exemption assessments.
In addition to reviewing the methodology guidance, one request for exemption will be evaluated during Pack 15: Cadmium in luminescent material for on-chip application on LED semiconductor chips.
3E Analysis
The previous review of the list of restricted substances resulted in the addition of four phthalates to Annex II, which must be restricted in EEE from July 2019.
Stakeholder consultations will be held in the course of these Pack15 evaluations, though none are scheduled yet. The project is set to run through 28 June 2019.