Proposed Additional RoHS Substances. Dr Paul Goodman

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1 Proposed Additional RoHS Substances Dr Paul Goodman C&R Sept. 2018

2 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

3 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

4 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

5 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

6 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 (Sb 2 O 3 ) 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?

7 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

8 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)

9 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!

10 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 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.

11 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

12 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

13 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 Beryllium oxide Aluminium nitride Silicon carbide Boron nitride Aluminium oxide Thermal conductivity 265 W/mK 180 W/mK 70 W/mK 60 W/mK 25 W/mK

14 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

15 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)

16 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. CoCl 2 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

17 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

18 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 _Description_RoHS_15_final.pdf

19 --- Electrical & Electronic Equipment and the Environment - Meeting the technical and regulatory compliance challenges Dr Paul Goodman Product Regulatory Compliance +44 (0) paul.goodman@rina.org November 2018, Heathrow