Hazardous Substance Environmental Information

EU RoHS2.0 exemption clause update

On March 5, 2020, the Official Journal of the European Union released (EU) 2020/360, (EU) 2020/361, (EU) 2020/364, (EU) 2020/365, (EU) 2020/366, revising RoHS2.0 Directive (2011/65 / EU) Annex III and Annex IV exemption clauses, of which the revised clauses of Annex III include clauses 9, 9 (a) -I, 9 (a) -II, 41; the revised clauses of Annex IV include Articles 37 and 41 and the newly added Article 44. This is mainly to revise the exemption period, and some clauses detail the exempted product category or use and give different exemption periods accordingly. Except for the newly added Article 44 exemption clause in Annex IV, the implementation date is September 1, 2020, and the implementation date of the other revised clauses is April 1, 2021.

EU ELV exemption clause update

On March 5, 2020, the Official Journal of the European Union issued (EU) 2020/362 and (EU) 2020/363, amending Articles 8 (e) and 8 of Lead in Annex II of the EU ELV Directive (2000/53 / EC) (f) (b), 8 (g), 8 (k) exemption clauses and Article 14 on hexavalent chromium, in which the exemption clauses on lead have updated the exemptions of 8 (e), 8 (f) (b) Validity period, 8 (g) clauses are updated to 8 (g) (i) and 8 (g) (ii), new 8 (k) clauses are added, and the exemption validity period of Article 14 regarding hexavalent chromium is updated. The revised directive entered into force on March 6, 2020, and each member country should be converted into national laws by April 5, 2020

EU launches public consultation on restrictions on perfluorohexanoic acid (PFHxA), its salts and related substances

On March 25, 2020, the European Chemicals Agency (ECHA) announced a public consultation on perfluorohexanoic acid (PFHxA) and its salts and related substances. The deadline for public consultation is September 25, 2020. The ECHA Scientific Committee welcomes Submit relevant comments before May 13, 2020 to help them discuss the proposal for the first time in June 2020. The object of the restriction clause in the proposal is: substances, mixtures and articles, and the adoption of this clause will be regarded as REACH The restriction clause was updated in Appendix XVII of the REACH Regulation.

EU launches public consultation on draft REACH restrictions

On March 25, 2020, the European Chemicals Agency (ECHA) began to regulate five cobalt salts (cobalt sulfate, cobalt chloride, cobalt nitrate, cobalt carbonate, and cobalt acetate), formaldehyde and formaldehyde releasing agents, and perfluorohexyl sulfonic acid. (PFHxS) and the draft restrictions on its salts and related substances for public consultation. The deadline for public consultation is May 25, 2020. The public consultation on the draft restriction clause is a later stage of public consultation. Once the draft is passed, the restriction clause Updated into Appendix XVII of REACH Regulation

On March 5, 2020, the Official Journal of the European Union issued several 2011/65 / EU amendment directives to update the exemption clauses of RoHS2.0. Among them, the amendment clauses of Annex III on 2011/65 / EU include 9, 9 (a) -I, 9 (a) -II, 41; the revised clauses in Annex IV are 37, 41, and the new exemption clause 44.

This time it is mainly to revise the exemption period. Some clauses detail the exempted product category or use and give different exemption periods accordingly. The new regulations will take effect on the 20th day after the announcement. Except that the implementation date of the newly added Article 44 exemption clause in Annex IV is September 1, 2020, the implementation date of the other revised clauses will be April 1, 2021.

Amendment 3 of RoHS2.0 Directive is as follows:

The amendments to Annex IV of the RoHS2.0 Directive are added as follows:

On March 3, 2020, the European Chemicals Agency (ECHA) announced a public review of five potentially highly concerned substances (SVHCs). The five substances reviewed this time were 1-vinylimidazole, 2-methylimidazole, butylparaben, bis (acetylacetonate) dibutyltin, and resorcinol. The public consultation will end on April 17, 2020, during which all stakeholders can submit comments to ECHA. Substances that pass the review will be included in the SVHC candidate list as the 23rd batch of substances.

On January 16, 2020, the European Chemicals Agency (ECHA) added four substances to the SVHC candidate substance list, including diisohexyl phthalate and 2-benzyl-2-dimethylamino-1- ( 4-morpholinephenyl) butanone, 2-methyl-1- (4-methylthiophenyl) -2-morpholinyl-1-acetone due to reproductive toxicity, and perfluorobutanesulfonic acid (PFBS) Due to its various characteristics, its salts have been added to the SVHC candidate substance list. So far, the SVHC candidate substance list includes 22 batches of 205 substances.

                              The 22nd batch of SVHC candidate substances

In 2019, the EU reported 2080 violations in 2019, of which 1090 reported violations originated in China, accounting for 52% of the total violations (see Figure 1 below).

Due to the launch date of electronic and electrical equipment (except medical monitoring equipment) from July 22, 2019, it needs to meet the new 10 requirements and add four new phthalate control, so the 2019 RoHS2.0 compliance was The EU law enforcement agency focused on verification. There were 75 notifications of violations of RoHS2.0 for RAPEX electrical and electronic equipment products. The product categories of RoHS2.0 violation notification in 2019 are mainly concentrated in product categories such as lighting equipment, headset communication and media equipment, and toy products. The reasons for the violation of RoHS2.0 in 2019 all come from the violation of the lead limit in solders, and more than half of the solders also exceeded the cadmium standard.

Figure 1: Data from the country where the violation was notified

Figure 2 RoHS2.0 violation notification data comparison over the years

Looking back at the data of the origin of Rapex violation notification cases in China in recent years, we found that in 2016, the source of products notified by Rapex in China accounted for a significant decrease from the previous year, and the source of products notified by Rapex in subsequent years The proportion of products has been maintained at around 50% (see Figure 3).

Figure 3: Rapex violation notification case with country of origin data

The five countries with the most frequent notifications are Germany, Hungary, France, the United Kingdom, and Poland (see Figure 4).

Figure 4: National data for initiating violation notifications

The product categories of high-frequency notification of violations include toys, motorcycles, electronic and electrical products, textiles, clothing and fashion products, and cosmetics (see Figure 5).

Figure 5 Product categories for violation notification

The reason for the high-frequency reported violation is that it can cause the following hazards: injury, chemicals, suffocation, electric shock, fire, and environmental hazards, of which 57% of the environmental hazards are reported as RoHS2.0 violations (see Figure 6).

Figure 6 Risk categories for violation notification

The violation of hazardous substances in electronic and electrical products in 2019 is mainly due to the violation of RoHS2.0 in lead and cadmium in solders, and the violation of POPs in SCCP in plastics and cables. In addition, phthalates in children's products exceed the standard; azo dyes in textile leather and hexavalent chromium exceed the standard; polycyclic aromatic hydrocarbons in the rubber material exceed the standard and lead, cadmium and nickel in metal parts in contact with the skin Excessive emission; excessive asbestos in thermal insulation; excessive volatile organic compounds such as chloroform, toluene, and xylene in adhesives; excessive nicotine in e-cigarette oil; excessive heavy metals in packaging and batteries also frequently occur These high-risk materials and projects require us to pay close attention to the control of hazardous substances to avoid trade risks caused by material violations.