On April 20, 2018, Oeko-Institut launched a stakeholder consultation on seven substances being evaluated to review and amend the list of restricted substances in RoHS Annex II under the project (Pack 15)

The substances under review include:

  • Cobalt Salts
  • Nickel Sulphate and Nickel Sulfamate
  • Indium Phosphide 
  • Beryllium and beryllium oxide 
  • Medium Chain Chlorinated Paraffins (MCCP)
  • Tetrabromobisphenol A (TBBP-A)
  • Diantimony Trioxide (ATO)

The final stakeholder meeting (webinar) for the Pack 15 project was held on the 27 April 2020.

The followings are the summary of the discussions.

1-    Cobalt Salts
The study confirmed that all five substances (Cobalt dichloride, cobalt sulfate, cobalt dinitrate, cobalt carbonate, and cobalt diacetate) are process chemicals and so will not occur in electrical equipment. The restriction was therefore not recommended.


2-    Nickel Sulphate and Nickel Sulfamate
The study confirmed that both substances are process chemicals and so will not occur in electrical equipment. The restriction was therefore not recommended. 


3-     Indium Phosphide 
A restriction was not recommended because of the relatively small amounts used in electrical equipment and because all substitutes are equally or more hazardous. 


4-    Beryllium and beryllium oxide 
Although beryllium poses a significant health hazard due to its toxicity, Oeko concluded that exposure due to end of life processes is very low due to the very small amount used. The conclusion of Oeko’s study was that beryllium and its compounds are not recommended for restriction by RoHS.


5-     Medium Chain Chlorinated Paraffins (MCCP)
MCCP is used as a flame retardant and plasticizer in PVC, rubber, and other plastics. Oeko proposed that MCCP should be restricted and be defined by carbon chain length as C14 – C17. However chemical screening analysis for MCCP is very difficult and no calibration standards exist, so manufacturers and market surveillance authorities would have difficulty analyzing materials. The Commission asked stakeholders to provide a suitable definition of MCCP that could be used that would include all commercially available types of “MCCP”.


6-    Tetrabromobisphenol A (TBBP-A)
Oeko is recommending that TBBP-A is restricted by RoHS at concentrations of more than 0.1% by weight in homogeneous materials. 


7-    Diantimony Trioxide (ATO)
Although Oeko recommended not to restrict ATO, they also recommend that a study is carried out in the future of a “group” of ATO and brominated flame retardant (BrFr). After discussion, stakeholders asked the Commission to confirm that there are currently no plans to reassess ATO in the future and any future study of BrFR’s would not consider restricting ATO.
 
Conclusions and next steps:

Final reports will be published on Oeko’s RoHS website and the Commission will assess the recommendations made by Oeko and comments submitted by stakeholders before reaching decisions on whether to add substances to Annex II of RoHS (the list of restricted substances) by delegated Acts. This process will be carried out in parallel with the current ongoing RoHS review which is due to publish proposals in July 2021.


More information


May 6, 2020, by Ahmad AbdElnaby