C&R Sept. 2018Dr Paul Goodman

Proposed Additional RoHS Substances

Agenda

Additional RoHS substances study

• Background to new restriction proposals

• Which substances have been proposed?

• What are their uses and do substitutes exist?

• Do they cause harm and is a restriction justified?

• Timescales of review and future restrictions

RoHS proposed

additional substances

Background

• Article 1 of RoHS:

• This Directive lays down rules on the restriction of the use of hazardous

substances in electrical and electronic equipment (EEE) with a view to

contributing to the protection of human health and the environment,

including the environmentally sound recovery and disposal of waste

EEE.

• It is the Commission’s job to adopt additional restrictions if these are

necessary to protect human health and the environment

• A study was carried out as part of the recast review by the Austrian UBA

to identify possible future substance restrictions

RoHS proposed

additional substances

• UBA study and methodology

• Methodology was developed by Austrian UBA for EC as part of the

recast review study

• The study was much criticised by industry

• Some aspects of methodology were good

• But, UBA used too many assumptions when data was not available to

make their recommendations on phthalate restrictions unreliable

• They also proposed a list of many substances for possible future

restriction

• List includes many substances that never occur in EEE

RoHS proposed

additional substances

• Note that the RoHS directive does not specify a methodology

• It only requires that a substance be hazardous

• No need to prove that harm is caused

• No need for alternatives to exist or replacement be feasible

• RoHS requires that the “Precautionary Principal” be taken into account,

but this should also be used for substitutes!

• Important that any new restrictions will genuinely protect health and

the environment. No action should be taken if a restriction will have

no benefit to health or the environment

• The approach used for REACH restrictions is different

• It is first necessary to prove that there is an uncontrollable risk of harm

to health and / or the environment

• Restrictions are targeted at preventing specific causes of harm

RoHS proposed

additional substances

Seven types of substances are proposed which are those identified by

Austrian UBA with the highest priority

Study by Oeko announced to consider possible addition to Annex II of:

• Diantimony trioxide (Sb2O3)

• Tetrabromobisphenol A - TBBPA

• Medium Chain Chlorinated Paraffins - MCCP

• Beryllium and its compounds

• Indium phosphide (InP)

• Nickel sulphate and nickel sulfamate

• Cobalt dichloride and cobalt sulphate

• Do you know if any of these occur in your products?

RoHS proposed

additional substances

Study is being carried out by the Oeko Institut

Part 1: Substance restriction:

‒ Task 1: Update the existing methodology to identify and assess substances for

possible restriction;

‒ Task 2: Assess substances with a view to their possible future restriction;

‒ Task 3: Determination of the quantitative usage data for substances used in EEE;

Parts 2 and 3 relate to exemptions, not covered here today

Proposed substance

Diantimony trioxide

• Widely used as a flame retardant (FR) synergist. It is usually used in flexible PVC and in

polymers that contain halogenated flame retardants - e.g. in very many types of

electronic components, mouldings, enclosures, etc.

• Will be difficult or impossible to replace in some uses.

• It may be necessary to use different types of polymers in some circumstances to

avoid diantimony trioxide and achieve UL94V0

• Diantimony trioxide is classified as a category 2 carcinogen (so cannot be a REACH

SVHC)

• EU risk assessment in 2008 concluded that it causes no harm to human health or the

environment and so there is no need for further measures

• This study included situations where high levels of diantimony trioxide occur such as

badly controlled recycling sites

• A more recent US study by the US EPA confirmed the EU results

• Diantimony trioxide is converted into the less hazardous antimony pentoxide during

thermal recycling (this is not a carcinogen)

Proposed substance

Diantimony trioxide

• It will be very difficult to replace diantimony trioxide

• Requesting exemptions can be slow, frustrating and difficult

• A restriction may encourage some manufacturers to relax fire retardancy

performance

• Fires due to electrical faults cause hundreds of deaths in the EU per year

• Precautionary principal would require that:

• If a restriction could increase the number of deaths and injuries from

electrical fires, the EU should not adopt this restriction

• Protection of health may require that diantimony trioxide is not

restricted!

Proposed substance

Tetrabromo-bisphenol A - TBBPA

• Reactive FR used in FR4 laminate, so not present in EEE

• Also used as a reactive FR in polycarbonate

• Limited use as additive FR in ABS, but ZVEI report that this is not used in the EU

• One publication showed that a PCB laminate contained only 0.7ppm of TBBPA

• EU carried out risk assessment in 2006 - 2008

• This concluded that TBBPA causes no harm to humans but may cause harm to the

environment and that this was mainly during manufacture and use of TBBPA, not

after it has reacted to form polymers or from waste polymers.

• A US Life Cycle Assessment has been published which shows that most alternatives to

TBBPA-laminates are not necessarily less harmful to the environment

• EU legislation that is for regulation of process chemicals is REACH, RoHS is not intended

to regulate process chemicals.

Proposed substance Medium chain chlorinated paraffins - MCCP

• The Swedish Chemical Agency KEMI recently carried out a comprehensive study and

recommended restriction of MCCP by RoHS

• Used as a plasticiser and flame retardant and is probably the most hazardous of the

substances being studied (aquatic acute and chronic toxin cat 1, may cause harm to

breast fed children)

• Mainly used in flexible PVC and rubber

• Structurally similar to SCCP that is banned by the EU POPs Regulation, but MCCP

is different and is less hazardous than SCCP

• Swedish study found that ~65% of uses in the EU are NOT in electrical equipment in

scope of RoHS – So, would REACH be more appropriate and effective if this substance

causes harm?

• Stakeholders report that substitution should be possible, as long as diantimony

trioxide is not also restricted

• Substitution requires replacement of MCCP by both a plasticiser and a flame

retardant

Proposed substances

Beryllium and its compounds

• Uses

• Beryllium oxide thermal conductor used as a semiconductor heat sink

• Beryllium metal X-ray windows

• Low electrical resistance, corrosion resistant alloys with superior tensile

properties. - CuBe, NiBe and AlBe alloys –

• Used for connectors, springs, thermostats, EMC gaskets, etc.

• Several independent studies show that beryllium outperforms all substitutes

where it is used

• German REACH study concluded - “Since substitution of Beryllium might

be impossible in most cases (including the problematic cases), a general

restriction does not seem to be the best option”.

• As beryllium is a scarce and expensive material, manufacturers use it only if

they cannot find an alternative. It is usually only used when no alternatives

exist

• If all uses require permanent exemptions, a restriction would be pointless

Proposed substances

Beryllium and its compounds

•Beryllium compounds – only its oxide is used in EEE

• Beryllium oxide used as a semiconductor heat conductor for ICs.

• Data included in submission from AEM shows:

Material Thermal conductivity

Beryllium oxide 265 W/mK

Aluminium nitride 180 W/mK

Silicon carbide 70 W/mK

Boron nitride 60 W/mK

Aluminium oxide 25 W/mK

Proposed substances

Beryllium and its compounds

• Beryllium metal and alloys

• X-ray windows

• Must be very low atomic number to be transparent to X-rays &

electrons – Be is 4

• Must not readily oxidise in air, so cannot use lithium metal with At. No.

3 (oxygen is At.No. 8)

• Lowest atomic number elements are gases - Hydrogen = 1 and helium

= 2

• At No 5 is boron and at. No 6 is carbon, - both too weak to support a

vacuum and will absorb X-rays and electrons

• CuBe spring alloys – e.g. used in connectors, etc. High creep resistance,

and low electrical resistance

• Could use phosphor bronze, CuTiFe, etc., but all apparent substitutes

to CuBe have different combinations of properties that affect

performance, lifetime and reliability

• Substitute alloys are cheaper so would already be used if they are

suitable

Proposed substances

Indium phosphide – semiconductor

• High-power and high-frequency electronics, mainly used in telecom sector

• Used in laser diodes and photodetectors

• InP semiconductor is difficult to use and expensive, so where it is

used, there will usually be no alternatives

• Quantum dots for displays (a claimed alternative to CdSe - exemption 39)

Proposed substances

Ni and Co salts

• Nickel sulphate and nickel sulfamate

• Used only as process chemicals, so a ban is pointless

• Used for electroplating nickel metal. There is no sulphate or sulphamate

present in EEE

• Nickel and its compounds are already restricted by REACH – Annex XVII

item 27

• Cobalt dichloride and cobalt sulphate

• Mainly / only used as process chemicals so a ban is pointless. CoCl2 may

rarely be used as an ink drier (probably discontinued)

• Used for cobalt metal plating and to make other cobalt chemicals

• Used in trivalent chromium passivation processes (as a substitute for CrVI

passivation) – traces of Cobalt ions may be present in coatings but may not

be possible to identify as chloride or sulphate

Proposed substances

Timescale and next steps

• Plan for Oeko study

• Stakeholder consultations May (complete) and later in 2018 (not

announced yet)

• Stakeholder meeting in November

• Study completion March 2019

• Commission can adopt new restrictions by amending Annex II. No need for

extensive negotiations with European Parliament and Member States

• Restrictions could be agreed and adopted within 1 – 2 years

• A transition period would be given. This was 4 and 6 years for phthalates.

• Industry would need to request new exemptions when restrictions are

published in the Official Journal and these will need to be agreed and

published before restrictions take effect

• This could take 3 – 4 years after submission if there are many needed

Conclusions

• Seven types of additional RoHS substances are proposed

• Several do not occur or only rarely occur in EEE

• Some have no substitutes where they are used

• Some cause no harm

• If restrictions are adopted, these could take effect by 2025

• Manufacturers will need to identify all uses, determine if substitutes exist

and will be reliable and if not, prepare and submit exemption requests at

the latest 3 years before the restriction takes effect

• Description of Oeko study at

http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_15/Project

_Description_RoHS_15_final.pdf

Electrical & Electronic Equipment

and the Environment

• ---

14-15 November 2018, Heathrow

Dr Paul Goodman

Product Regulatory Compliance

+44 (0)1372 367221

paul.goodman@rina.org

- Meeting the technical and regulatory

compliance challenges