The Oko Institut, based in Germany, and who is carrying out the review of additional RoHS substances for the European Commission (EC), has published a list of 46 substances, plus all brominated flame retardants, that are now subject to stakeholder consultation.
However, there is limited time to reply as their draft final report is due by the end of April. Before this time all technical issues need to be considered. At present, there is no appeals procedure expected against Oko’s recommendations.
Oko will also consider whether or not it is more appropriate to restrict substances under the REACH Regulations as REACH is based on risk assessment whereas RoHS is focussed on hazard. Both can restrict substances in equipment.
The selection criteria for the substances open to consultation was more typical of REACH than RoHS.
Oko are looking for hazardous substances used in electrical and electronic equipment for which substitutes are available. Apparent substitutes may not have the comprehensive health and environmental data so, potentially, could be even more harmful. In this respect, the REACH risk assessment approach maybe more beneficial.
Likely candidates to be restricted include arsenic, beryllium, DEHP (a common plasticiser) and Biphenyl A, used in epoxy resins.
The EC review will also cover potential new product categories. Medical and Monitoring & Control Instruments, categories 8 and 9 of the WEEE Directive will be recommended for inclusion around 2012. ERA, who carried out this review, also recommended a further 20 associated exemptions.
Definitions such as “fixed installations” and “spare parts” are also expected to be clarified as “RoHS2” is announced.
Directive Decoder
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