EC Seeking Comment on RoHS Exemptions

Electrical and Electronic Equipment Restrictions

Electrical and electronic equipment (a/k/a ‘EEE’) are pervasive in our modern world, from large household appliances to smartphones and medical devices. In the European Union, EEE are subject to the restriction of certain hazardous substances under Directive 2011/65/EU, the so-called ‘RoHS’ Directive, which currently restricts a total of six substances from being included in such equipment above a certain concentration (lead, mercury, cadmium, hexavalent chromium, and two halogenated flame retardants).

European Commission Modification to RoHS

In 2015, the European Commission adopted Directive (EU) 2015/863, to modify RoHS to additionally restrict the presence of four different phthalate plasticizers in EEE. The new RoHS Directive will take effect in either 2019 or 2021, depending on the type of EEE in scope. While a number of exemptions are currently offered (e.g. hexavalent chromium in refrigerators; mercury in general lighting devices, etc.), the European Commission (EC) are currently reviewing a number of these exemptions, to determine whether they should be maintained under the new RoHS Directive. Stakeholders interested in communicating their concerns to the EC have until the end of August to submit their comments.

Implications for Manufacturers and Importers

If the EC removes the current exemptions for certain applications of cadmium, hexavalent chromium and lead, manufacturers, and importers placing certain EEE on the market in EU would need to reformulate their products with a safer alternative substance, else use less than whatever threshold quantity is currently allowed in the component.
With reformulation comes reassessment of the new formulation’s hazards, and development of associated documents, such as SDS and labels.

Whether you’re looking for guidance on how to prepare SDS for your shipments to Europe, or you simply need assistance with other chemical compliance matters, Global Safety Management and its team of experts is here to help. Questions? Contact us today!