EU RoHS

September 20, 2022 | Written by GreenSoft Technology, Inc.

Two New Substances Proposed to be Added to EU RoHS Directive

European Commission expected to announce inclusion of 2 new substances to EU RoHS Directive by end of 2022

The European Commission is currently reviewing a consultant report by the Oeko-Institut which recommends adding two new substances for restriction under the EU RoHS Directive.

It is expected that the European Commission will agree with the consultant recommendation to include the substances in the EU RoHS Directive. The European Commission is expected to announce their decision by the end of this year.

The two substances are:

• Medium chain chlorinated paraffins (MCCPs)
• Tetrabromobisphenol A (TBBP-A)

MCCPs are used in electrical and electronic equipment (EEE) mostly as constituents of PVC insulations for electric cables and wires and other soft plastic or rubber components, including polyurethane, polysulphide, acrylic and butyl sealants.

The primary use of TBBP-A is as a precursor in the production of brominated epoxy resins that function as reactively flame-retarded substrate in printed wiring boards (PWB). It is also used as an additive flame retardant in thermoplastic EEE components, for example housings that consist of ABS plastic.

The path to implementation

The consultant report which recommends to add MCCPs and TBBP-A to the EU RoHS Directive was part of the Pack 15 review, which studied seven substances total. In November 2020, the Oeko-Institut completed the Pack 15 review and issued their final report, which recommended to add these two substances out of the seven total substances under review.

In May 2022, the European Commission launched an official initiative to propose adding the two substances to EU RoHS based on the Oeko-Institut recommendation. It is anticipated that the European Commission will adopt the proposal.

The initiative is expected to be completed in by the end of 2022. At that time, an amendment to the EU RoHS Directive would be published to the Official Journal and the substance additions become official.

The deadlines for implementation for affected companies currently using MCCPs and TBBP-A is still unknown. When four phthalates were added to EU RoHS in June 2015, a period of four years was provided before the restrictions began to take effect. While it is unclear how long affected companies will be given for implementation of these new substance additions, it is expected that some form of implementation period will be provided.

GreenSoft Technology will continue to track the status of the substance additions to the EU RoHS Directive, and will publish updates on our blog.

The new substances are part of RoHS-2

The restriction of MCCPs and TBBP-A under EU RoHS will be adopted as an amendment to the EU RoHS Directive, just as the addition of the four phthalates in June 2015 was adopted as an amendment.

Although the RoHS-2 regulation with the four phthalates is sometimes referred to within the industry as RoHS-3, it is still officially considered the RoHS-2 regulation by the European Commission.

The EU RoHS Directive will remain as RoHS-2 until such time as it is recast by the European Commission, regardless of additional amendments to include new substances.

Such a recast may be coming in the near future, as the European Commission did launch a public consultation period to review the EU RoHS Directive rules in March 2022. Learn more on that review period here.

GreenSoft can help with EU RoHS

GreenSoft Technology provides Data Services and GreenData Manager software to help your company comply with the EU RoHS Directive.

We will collect compliance data on parts and assemblies from your supply chain for you, so that you can show due diligence while still focusing on your core competencies. Compliance and completion reports can be generated for you by GreenSoft Technology, or by using GreenData Manager software.

Learn more and receive a free Risk Analysis when you contact us.