Here we introduce the new kids on the proverbial RoHS Restriction Block, and how their addition to the list may impact EEE producers.
The 2006 Restriction of Hazardous Substances - or RoHS – Directive, and its 2013 revised version , currently restricts the use of four heavy metals (lead, cadmium, mercury, hexavalent chromium) and two categories of brominated flame retardants (PBBs and PBDEs) in electrical and electronic equipment (EEE).
To further protect human health, and to support the environmentally-safe recovery and disposal of waste electrical and electronic equipment (WEEE), this latest directive introduced a gradual ‘phasing in’ of product categories which will eventually include all EEE, cables and spare parts by 2019.
And that’s not all.
On the 4 June 2015, Commission Directive (EU) 2015/863 added four new substances to the list of RoHS restrictions, updating Annex II of the legislation with Bis(2-ethylhexyl) phthalate (DEHP), Benzyl butyl phthalate (BBP), Dibutyl phthalate (DBP), and Diisobutyl phthalate (DIBP).
What are phthalates?
Phthalates are a group of chemicals used to make plastics softer, more flexible and therefore harder to break. There are several different kinds and their use is phenomenally widespread: everything from soaps and shampoos, to adhesives, vinyl flooring, raincoats, toys and even food.
Used as plasticizers in plastics such as soft PVC, they can also be found in wires and cables, some electronic components and other plastic parts.
Phthalates are not chemically bound to the materials they're added to, so individuals can be exposed to them through inhalation (indoor air), ingestion (via food) and contact through skin.
Why are phthalates restricted?
Because of their common use in consumer items, concerns over human exposure to phthalates have been addressed by REACH, the EU regulation on the management and safety of chemicals.
REACH now restricts DEHP, DBP and BBP in all toys and childcare articles, and all four phthalates are on its “Candidate List” (substances of very high concern). They are also only authorised for specific uses.
The additional restriction through RoHS recognises the use of phthalates in electrical and electronic equipment, and the potential danger to humans and the environment when these substances end up in landfill sites, or are released during the recycling process.
What restrictions come into force and when?
The new restrictions for phthalates DEHP, BBP, DBP, and DIBP will come into effect beginning 22 July 2019 for all EEE, except medical devices and monitoring and control instruments which will need to comply by 22 July 2021.
A maximum concentration value of 0.1% in homogeneous material is consistent with other substance restriction levels in RoHS (for lead, mercury, hexavalent chromium, PBB and PBDE).
Who is impacted by the legislation?
If your company manufactures and sells or resells under your own brand, imports or exports electrical goods in the EU, you are likely to be affected by RoHS regulations.
Obligations include a conformity assessment of the equipment, drafting a technical file and declaration of conformity, as well as CE marking and labeling. Producers and distributors also have specific record keeping and compliance monitoring requirements.
Documents must be kept for up to ten years and be made available to customers on request, and it is the responsibility of anyone who sells EEE that non-compliant products are withdrawn from the market, and that the authorities are notified.
Where to get more information
Detailed information can be found on the UK government RoHS website.
If you have questions regarding RoHS or REACH regulations, and would like to know how you could be affected, contact the ecosurety team on 0845 094 2228 or email firstname.lastname@example.org.
International compliance product manager
Fran works within the compliance team as our international compliance product manager, joining us in the spring of 2015. She brings a wealth of experience to the role having previously work for Apple in Ireland for six years, looking after the company’s WEEE, battery and packaging submissions across Europe. Needless to say she has gained extensive knowledge of European legislation!
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