IPC Submits Comments to EU Commission on Draft RoHS Annex 2 Dossiers

Today, IPC submitted comments to the European Union (EU) Commission on the Draft RoHS Annex 2 Dossiers for HBCCD, DEHP, BBP and DBP. The European Union Commission’s Directorate General (DG) for Environment is currently revising the list of substances restricted under the RoHS Directive. While the current review is limited to HBCDD (a flame retardant) and three phthalates already restricted under REACH, the dossiers are still important as they like will serve as a model for assessments of additional prioritized substances, including TBBPA.

In a separate report, the Commission’s consultants have developed a prioritized list of additional substances to be reviewed for restriction under RoHS, which includes TBBPA, the most common flame retardant in printed boards, as a priority substance. It is likely that additional substance dossiers will be submitted by EU Member States by July 2016, triggering a review of those substances.

Within its comments, IPC expressed concern that the dossiers contain a significant amount of inaccurate information and flawed assumptions. In particular, IPC expressed concern that the reports focused on irrelevant data from uncontrolled waste treatment in developing nations, and assumed that a complete change in the flame retardant and laminate system would have no cost impact for EEE producers.

IPC concluded that the presented dossier for HBCCD is significantly flawed and cannot be used in its present form for a rational, science-based evaluation. Given the flaws presented in this and other dossiers, IPC strongly recommended further development of evaluation criteria and methodology prior to any future substance reviews.

See complete comments.

IPC will continue its advocacy efforts to promote science-based and cost-effective regulations.

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