EU RoHS Proposal for MCCP and TBBP-A

EU Proposes Two New Additions

Any company that sells electrical or electronic equipment, assemblies, cables, components, or spare parts into the European Union, as well as their distributors or resellers, needs to be aware of the RoHS (Restriction of Hazardous Substances) Directive and all iterations of the regulation since 2005. The most recent versions of the regulation including EU-RoHS Directive 2011/65/EU and amendment 2015/863 have the goal of preventing risks to human health and the environment by restricting the use of hazardous substances in electrical and electronic equipment.

10 Restricted Substances

To date as of 2023, the official number of substances on the list stands at 10. This list does not change frequently and tends to have much deliberation. More focus is placed on exemption management and sunset dates. However, the directive is under review for a major change in the upcoming years and may be promoted to a regulation.

In 2006, the RoHS Directive included 6 materials for restriction.

Lead (Pb) (≤ 0.1 percent or 1,000 ppm)

Mercury (Hg) (≤ 0.1 percent or 1,000 ppm)

Cadmium (Cd) (≤ 0.01 percent or 100 ppm)

Hexavalent chromium (CrVI) (≤ 0.1 percentor 1,000 ppm)

Polybrominated biphenyls (PBB) (≤ 0.1percent or 1,000 ppm)

Polybrominated diphenyl ethers (PBDE) (≤0.1 percent or 1,000 ppm)

In 2015 and enforced in July 2019, the RoHS Directive included 4 additional materials.

Bis(2-ethylhexyl) phthalate (DEHP) (≤ 0.1percent or 1,000 ppm)

Benzyl butyl phthalate (BBP) (≤ 0.1percent or 1,000 ppm)

Dibutyl phthalate (DBP) (≤ 0.1 percent or1,000 ppm)

Diisobutyl phthalate (DIBP) (≤ 0.1percent or 1,000 ppm

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MCCP and TBBP-A

In May of 2022, the European Union published an initiative to add medium chain chlorinated paraffins (MCCPs) and Tetrabromobisphenol A (TBBP-A) to the list of RoHS restricted materials. The adoption time was set for fourth quarter of 2022.

According to the Oeko Institut, MCCPs are considered to have persistence, bioaccumulation, and toxicity. This is often referred to as PBT. TBBP-A is considered to be very persistent and very bio-accumulative. This is often referred to as vPVB.

Both MCCPs and TBBP-A are considered pervasive pollutants that can cause unacceptable risks to human health during waste disposal and recycling. These materials are most often found in electrical and electronic equipment. Hormonal disruption is one of the many problems caused by these materials.

For reference, when using the CAS Registry - MCCP is CAS 85535-85-9. TBBP-A is CAS 79-94-7.

Common Uses

MCCPs are used as a flame retardant in plasticizers during the production of flexible plastic and rubber products, such as filaments, cables, and rubber sealants. It is also found in PVC, coatings, adhesives, and sealants. Most often, it used as a secondary plasticizer to extend PVC. MCCP is also being considered for addition to the EU REACH regulation.

TBBP-A is utilized as a flame retardant enclosure for electrical and electronic products. It is often used as a brominated epoxy resin used as a flame retardant in printed wiring boards. It can also be an additive in thermoplastics.

Compliance Guidance

As we await a final inclusion of MCCP and TBBP-A, it is important that all manufacturers are proactive and determine whether or not their parts or products have the potential risk of containing these two materials.

If the part or product contains the material, then it is important to ask suppliers for compliance declarations stating the amount of regulated material in their product. If the declared content is greater than 0.1% at the homogeneous material level, then this must be communicated to each level of the supply chain . this includes communication to the finished goods company that places product on the market in Europe.

It is also critical that we follow the EU REACH regulation for further guidance on MCCPs. It may be necessary to build a proactive plan for mitigating the risks associated with MCCP content above 0.1% in an article.

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Be Pro-Active! Identify the risks of MCCP and TBBP-A today. Call us Now!

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Links

EU RoHS Directive

Oeko Institut Report

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