The Austrian Environmental Agency (UBA) recently published their final report on the methodology for reviewing substances for potential restriction under the EU RoHS Directive. The report, along with four substance restriction dossiers (HBCDD, DEHP, BBP, DPB), an inventory of substances used in electrical and electronic equipment (EEE), and a prioritized list of substances to be reviewed for possible restriction, were prepared for the European Commission (EC).
In addition to participating in several stakeholder meetings, IPC filed formal comments on the draft methodology and HBCDD dossier.
IPC is deeply disappointed that Tetrabromobisphenol A (TBBPA) continues to be identified as a substance of high priority for assessment and potential restriction under RoHS. As noted in our March 11, 2013 comments to the UBA, a comprehensive EU risk assessment found the use of TBBPA does not present a risk to human health and the environment. The UBA report cites circular logic and a single, unsubstantiated report as the basis for listing TBBPA as a priority substance.
In our November 25, 2013 comments, IPC expressed concern that the substance dossiers (assessments) 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. Although the final dossiers acknowledge stakeholder comments, the findings were unchanged.
On June 10, 2013, IPC submitted comments on the second draft of the methodology stressing the importance of evaluating both hazard and exposure characteristics of a substance and potential alternatives prior to restricting a substance.
During the RoHS revisions process IPC successfully lobbied for the revised Directive to be scientifically based. As a result, the EU did not implement additional substance restrictions under the revised RoHS Directive, but the EC was required to complete a review of Annex II by July 2014.
IPC will remain engaged in the review process and will continue to advocate for science based regulations.