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Study on hazardous substances in electrical and
electronic equipment, not regulated by the RoHS
Directive
Expert Workshop Brussels 6 May 2008
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Background and Objectives

• RoHS Article 4 (3) as soon as scientific
  evidence is available, and in accordance with the
  principles on chemicals policy EU bodies shall
  decide on the prohibition of other hazardous
  substances and the substitution thereof by more
  environment-friendly alternatives which ensure at
  least the same level of protection for consumers
• Study shall provide the necessary support to the
  Commission services by investigations on
• Inventory of other hazardous substances in EEE
• Risk management of hazardous substances
• Possible Substitutes
• Policy options for candidate substances

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Inventory of hazardous substances in EEE

• Information on hazardous substances in EEE
• Identification of high priority substances
• Allocation to electrical electronic components
• Typical content of hazardous substances in
  components
• Allocation to typical EEE products
• Allocation to WEEE categories
• Annual flow of hazardous substances in EEE

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Criteria for selection of high priority
substances (I)

• 1) Substances of very high concern (SVHC) as
  defined by REACH
• Carcinogenic category 1 or 2
• Mutagenic category 1 or 2
• Toxic for Reproduction category 1 or 2 (CMR)
• Persistent, Bioaccumulative Toxic (PBT)
• very Persistent very Bioaccumulative (vPvB)
• Endocrine Disrupters (ED)

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Criteria for selection of high priority
substances (II)

• 2) Substances found as contaminants in humans and
  biota raising concern regarding potential
  long-term harmful effects
• 3) Substances forming hazardous substances during
  the collection and treatment of EEE (e.g. during
  incineration)

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Criteria for selection of high priority
substances (III)

• Substances which fulfil one of the criteria 1 3
  have potential to cause severe harm to humans
  and/or the environment
• High priority substances

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Criteria for selection of high priority
substances (IV)

• Substances classified as dangerous according to
  Annex I of Directive 67/548, but not fulfilling
  criteria 1 3
• and
• Substances which are already regulated by
  existing legislation
• have been documented but have not been further
  evaluated.

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Risk management of high priority hazardous
substances

• Exposure to humans and environment and resulting
  risks
• Monitoring data in human, other biota and
  environmental media
• Relevance of EEE with regard to total
  consumption
• Availability of substitutes
• Identification of substances that have major
  impacts on environment and human health by
  combination of intrinsic properties and exposure
  
• ? Candidate substances for potential inclusion in
  RoHS

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Proposed candidate substances for potential
inclusion in RoHS
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Allocation of HS to electrical and electronic
components
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Allocation to electrical and electronic components
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Allocation of HS to electrical and electronic
componentsdata gaps
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Allocation to (typical) EEE products
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Allocation to (typical) EEE products data gaps
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Allocation to WEEE categories
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Possible substitution of candidate
substancesTBBP-A
Substitution of TBBP-A in printed circuit boards
(I) Substitution of TBBP-A by non-halogenated
reactive FR, e.g.- DOPO (Dihydrooxaphosphaphena
ntrene) and its derivates which are cyclic
hydrogenphosphinates - Poly(1,3-phenylene
methylphosphonate) in combination with
Aluminium-tri-hydroxide (ATH) or
Aluminium-oxide-hydroxide (AOH)
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Possible substitution of candidate
substancesTBBP-A

• Substitution of TBBP-A in printed circuit boards
  (II)
• Substitution of TBBP-A by non-halogenated
  additive FR, e.g.
• Metal phosphinates used in combination with
  N-synergist such as Melamine polyphosphate, with
  modified (phosphorus or nitrogen containing)
  epoxy resin or blend with other polymers
• Metal hydroxides e.g. Aluminium Trihydroxide
  (ATH, Al(OH)3) Alumina monohydrate (AlOOH)

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Possible substitution of candidate
substancesTBBP-A

• Substitution of TBBP-A in printed circuit boards
  (III)
• Use of inherently flame-retardant, halogen-free
  base materials
• - Thermosetting plastics e.g. epoxy-novolac
  resins- Thermoplastic resins e.g. PEI
  (Polyether Imide) and PES (Polyethersulfone).

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Possible substitution of candidate
substancesTBBP-A

• Substitution of TBBP-A as additive FR in ABS used
  for electronic enclosures (I)
• by phosphorous based flame retardants in
  combination with PC/ABS and PPE/HIPS blends
• Tri-phenyl phosphate (TPP)
• Resorcinol bis (diphenyl phosphate) (RDP)
• Bis-phenol A bis(diphenyl phosphate) (BDP)

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Possible substitution of candidate
substancesHBCDD

• Substitution of HBCDD as additive FR in HIPS used
  for electronic enclosures / housings of EEE
• by phosphorous based flame retardants in
  combination with PC/ABS and PPE/HIPS blends
• Tri-phenyl phosphate (TPP)
• Resorcinol bis (diphenyl phosphate) (RDP)
• Bis-phenol A bis(diphenyl phosphate) (BDP)

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Possible substitution of candidate
substancesDEHP, BBP and DBP (I)

• Alternative plasticizers in PVC
• adipates (esters of adipic acids mainly
  Diethylhexyl adipate (DEHA) and
  Di-isononyladipat (DINA)),
• citrates (esters of citric acids mainly
  O-acetyl tributyl citrate (ATBC))
• (organo)phosphates Di(2-ethylhexyl)phosphat,
  Tri(2-ehtylhexyl) phosphat
• trimellitate Tri-2-ehtyl-trimellitate
• epoxidised soybean oil

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Possible substitution of candidate
substancesDEHP, BBP and DBP (II)

• Alternative plastics showing elastic properties
  without addition of plasticizers
• Polyethylene (PE)
• Polypropylene (PP)
• Polyurethane (mostly used as PVC substituting
  material in non EEE applications)
• Ethyl-Vinylacetate-Copolymere (EVA)
• ? For most of the flexible-PVC products
  alternatives free of plasticizers are available.

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Possible substitution of candidate
substancesMCCP SCCP
Only limited information available on substitutes
for MCCP and SCCP. ? further research required
to identify suitable substitutes.
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Possible substitution of candidate
substancesNonylphenol ethoxylates

• already been replaced in many application
  areas.
• reasonable to assume that for the remaining
  small-volume applications for EEE substitutes
  are available
• additional information is required from the
  manufacturers.

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Possible substitution of candidate
substancesOrganochlorine and organobromine
compounds

• See substitutes proposed for TBBP-A and HBCDD.
• Within this study not possible to analyse
  availability of substitutes for all
  organochlorine and organobromine compounds.
• Several manufacturers of EEE intend to phase-out
  brominated flame retardants (BFR) and PVC in all
  their applications ? substitution of
  organohalogen compounds in EEE is possible

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RoHS versus REACH RoHS and REACH !
RoHS Focus on hazardous substances in EEE as
defined in Dir 67/548/EEC REACH Registration,
evaluation, authorisation and restriction of
chemicals Broad scope, not focussing on specific
sectors REACH Authorisation related to
substances of very high concern 3 step
procedure Art. 57 / Annex 13 Definition of
substances of very high concern Art. 59
Candidate list Art.58 Priority setting for
inclusion of substances in Annex XIV. No
automatism of placing all SVHC into candidate
list / into Annex XIV Priority setting includes
PBT/vPvB criteria / wide dispersive use / high
production Volume chemicals REACH will consider
sector-specific regulations such as
RoHS Coexistence of REACH and RoHS.
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Overview on possible policy options (outlined by
EU Commission)

• Not add any new justified substances under RoHS
  and deal with them under REACH
• Add new substances but only for certain
  categories of EEE in the scope of RoHS
• Add new substances for all EEE, in the scope of
  RoHS but with exempted applications
• Add new substances for all EEE without exemptions
  at a deferred date
• Add new justified substances under RoHS only if
  substitutes already available and fully
  investigated
• Link inclusion of substances at a given deadline
  (e.g. 2014) with the results of a report on the
  efficiency of waste (WEEE) management for
  removing hazardous substances from the waste
  stream
• Not add any new substances but introduce
  labelling requirements (for example certain
  phthalates for certain Medical Devices)
• Not add any new substances but introduce
  obligation for easy removability of parts
  containing hazardous substances

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Proposed policy options for candidate substances
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Proposed policy options for candidate substances
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Further proposed policy options

• For Be and BeO the following policy options are
  proposed to support the safe recycling of
  Be-containing EEE
• Be and BeO containing EEE should be labelled
  exempted from this labelling requirement are
  Be-containing alloys with up to 2 w/w Be
• Be and BeO containing parts (exceeding 2 w/w
  Be) should be easily removable during
  dismantling of the EEE.

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Need for clarification
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Central Questions for the discussion (I)

• Substitution
• Do alternative technologies and/or EEE exist
  without the proposed candidate substances? Status
  of research development. What is a feasible
  phase-out timeline?
• Which effects does a restriction of hazardous
  substances have on innovation and research with
  regard to use of substitutes and/or alternative
  technologies?

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Central Questions for the discussion (II)

• Environmental and social impacts
• What are the environmental (e.g. energy use,
  toxicity, impact on waste stream), health (e.g.
  occupational health) and / or consumer safety
  (e.g. emissions) impacts caused by substitution
  compared to the ones of the proposed candidates?

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Central Questions for the discussion (III)

• Economic impacts
• Which costs will arise through the restriction of
  the proposed candidate substances in the supply
  chain both for industry and consumers?
• Which advantages/disadvantages will the
  restriction of the proposed candidate substances
  have on the competitiveness of industry on the
  internal and external market?

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Central Questions for the discussion (IV)

• Enforcement
• Practical workability and enforceability of
  restrictions?
• What are the administrative costs to enforce the
  restrictions?

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Further proceeding

• Clarification of open points
• Incorporation of results of expert workshop in
  draft final report
• Deadline for submission of additional information
  by experts20 May 2008
• ? Final report 4 June 2008