January 21, 2015
The European Commission (EC) Delegated Directive proposed will amend Annex II to Directive 2011/65/EU (RoHS 2) of the European Parliament and of the Council as regards the list of restricted substances.
RoHS 2 currently restricts the use of lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls, polybrominated diphenyl ethers in electrical and electronic equipment (EEE) and includes provision for delegated directives to amend this list.
This draft Commission Delegated Directive concerns the addition of three phthalates and one flame retardant; Hexabromocyclododecane (HBCDD), Bis (2-ethylhexyl) phthalate (DEHP), Butyl benzyl phthalate (BBP) and Dibutyl phthalate (DBP) to be considered as a priority and added to the list of restricted substances within the Directive. DEHP, BBP, DBP are three common phthalate plasticizers. HBCDD is a brominated flame retardant.
Although there are action limits for phthalates in REACH, these requirements are different as they introduce actual limits in homogeneous parts of EEE.
Why It Matters
HBCDD is a brominated flame retardant and a Substance of Very High Concern (SVHC). It is persistent and undergoes long range transport, accumulates in the food chain and is reprotoxic.
DEHP is a common plasticizer, sometimes used in PVC, and is considered a SVHC. It is a widespread environmental pollutant, found in the food chain and in the human diet. The majority of environmental releases of DEHP from relevant WEEE treatment processes are releases to air.
BBP and DBP are plasticizers, are considered as SVHC, and classified as toxic to reproduction. A risk for workers was identified for DBP for industrial processes in Europe in 2003, with concerns for general systemic toxicity as a consequence of repeated dermal exposure arising from aerosol forming activities, as well as concerns for adverse local effects in the respiratory tract as a consequence of repeated inhalation exposure. The majority of environmental releases of BBP and DBP from relevant WEEE treatment processes are releases to air.
The objective of the restriction is to phase-out SVHC in EEE in order to facilitate recycling and reduce possible negative impacts on human health and the environment, while granting economic operators adequate transition time for compliance.
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