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SGS Informs on the New RoHS Methodology Manual for Restricted Substances List

According to Recital 10, of EU Directive 2011/65/EU (RoHS), the use of the following substances should be considered as a priority for the first review, which must be completed before 22 July 2014.

Fairfield, NJ, February 07, 2014 --( Identification and Assessment of Hazardous Substances

These substances should be reviewed periodically thereafter by the European Commission, on its own initiative or following the submission by a Member State:

- Hexabromocyclododecane (HBCDD) a Brominated Flame Retardant
- Bis (2-ethylhexyl) phthalate (DEHP) a commonly used plasticizer
- Butyl benzyl phthalate (BPP) a commonly used plasticizer
- Dibutyl phthalate (DBP) a commonly used plasticizer

A Methodology Manual (1) was developed with the purpose of providing a documented methodology for “making decisions about inclusion of substances in ANNEX II based on scientific evidence and taking into account principles established under REACH.”

The Methodology Manual makes the following statements relative to the relationship of RoHS and REACH.

The REACH regulation “registration, evaluation, authorization and restriction of chemical substances” regulates chemical substances on their own, in mixtures or in articles. Recital 16 of RoHS states that information, generated by REACH, should be used by the relevant actors in the application and implementation of appropriate Community legislation, for example those covering products.

RoHS is a sector specific directive stipulating rules on the restriction of certain hazardous substances in Electronic and Electrical Equipment (EEE). There is neither a legal mandate nor an obligation to copy the procedure of substance restriction under REACH and involve ECHA and its scientific committees; Committee for Risk Assessment (RAC), Socio-Economic Analysis Committee (SEAC). However, information generated by REACH will be used for the restriction process under RoHS. As outlined above it can also be expected that inclusion in ROHS2 can be selected as the appropriate Risk Management Option (RMO) for specific Substances of Very High Concern (SVHC).

Overview of the Methodology Manual under RoHS and REACH

Part I Identification of Substances
Identification of substances used in EEE, which may have negative impacts on human health, the environment or resource efficiency during WEEE management according to RoHS Article 6 (1) a, b, and c)

Part II Pre-Assessment of Substances
Pre-assessment: Prioritization of substances used in EEE, which may most likely have negative impacts on human health, the environment or resource efficiency during WEEE management according to RoHS Article 6 (1) a, b, and c)

Part III Detailed Assessment of Substances
Detailed assessment of high priority substances with the view to a potential restriction under RoHS2

The output of applying the Methodology Manual resulted in the identification of the following substances and associated priorities. Please refer to 2nd Interim Report (2) for the complete report. Reference to this report is to point out that there are additional substances that have been identified that could be added to the substances restricted in addition to the four identified as a priority.

Hazardous Substances to Be Evaluated under RoHS and REACH

Public consultations (4) on the assessment of selected substances have been initiated to evaluate the first set of substances HBCDD, DEHP, BBP and DBP to be potentially included in RoHS 2, Annex II. The period of this public consultation is ended in November and stakeholders have been invited to contribute to the evaluation.

The results of the public consultation will be published in a final report on the developed methodology for identification and assessment of substances. Additionally the conclusion of the identification and assessment as well as draft recommendations for inclusion of substances in the list of restricted substances of RoHS 2 will be presented.

Having an understanding of substances which are currently being evaluated or restricted is important but it is equally important to understand the process which will be used to identify and prioritize substances for RoHS, REACH, and other emerging requirements. A supplier of substances, components, and or raw materials could identify these substances and begin the process of “Alternative Substance Assessment” or as it is sometimes identified “Green Chemistry” before the substances are actually restricted or not authorized for use. This proactive evaluation can allow a company to “get ahead” and begin to remove these substances from their products on their own timetable.

About SGS Electrical and Electronics Services

SGS is committed to keeping readers up to date on the latest regulations and policies concerning the use of hazardous substances in consumer products. Furthermore, through its global expertize and network of chemical labs, SGS can provide support in ensuring that products comply with relevant hazardous substances requirements on all relevant markets around the world.

Whether for hazardous substances testing ( or other third party verification, certification or inspection services, SGS is ideally positioned to satisfy all business's needs.

Feel free to contact an SGS expert should you require more information.

Contact details:

SGS Consumer Testing Services
Kenneth Stanvick
Environmental Compliance Management
Senior Consultant
Electrical and Electronics
SGS North America Inc.

t: +1 603 305 4103

SGS is the world’s leading inspection, verification, testing and certification company. SGS is recognized as the global benchmark for quality and integrity. With more than 75 000 employees, SGS operates a network of over 1 500 offices and laboratories around the world.
Contact Information
Kenneth Stanvick
+1 603 305 4103
SGS North America Inc.

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