“RoHS3” is on its way…
On June 4th, 2015 EU Commission published Delegated Directive EU 2015/863 in the EU Official Journal. This Directive adds four phthalates to the RoHS restricted substances, to be restricted in 2019. The four phthalates under this Commission Delegated Directive, also to be known as “RoHS3”, are likely to be found in myriad soft rubber parts and PVC. If you have soft plastics and PVC in your products, it’s highly likely that these phthalates exceed the maximum concentration value of .1% homogenous material weight. These phthalates are likely the be lurking in plastics, vinyl, labels, inks, synthetic rubber, epoxies, paints, sealing agents, coatings, adhesives and glues, polymers, polymer resistors, cables, wiring, handle grips, modeling clay, gaskets, rubber knobs and feet, and other materials.
After the implementation of this legislation (December 2016), updated/new declarations of RoHS3 compliance may be required. Written Declarations of Compliance may require a separate compliance statement to include these substances. Suppliers may need to refer back to their raw materials suppliers for RoHS3 compliance specifically for these four phthalates. The maximum concentration value of these substances is 1,000 ppm in homogenous material (0.1% weight per homogenous material).
The four phthalates CAS numbers, and common uses are:
· Bis (2-ethylhexyl) phthalate (DEHP): CAS # 117-81-7
- Uses: used as plasticizer in manufacturing of articles made of PVC
· Butyl benzyl phthalate (BBP): CAS # 85-68-7
- In addition to PVC plasticizer, used in adhesives and glues, vinyl floor coverings
· Dibutyl phthalate (DBP): CAS # 84-74-2
- In addition to PVC plasticizer, used in printing inks, adhesives, sealants/grouting agents, nitrocellulose paints, film coatings and glass fibers
· Diisobutyl phthalate (DIBP): CAS # 84-69-5
- In addition to PVC plasticizer, used in nitro cellulose plastic, paints, printing inks and adhesives, lacquer manufacturing
For parts with declared Full Material Disclosure (FMD), the CAS numbers for these four phthalates are often buried in polymers, epoxies and PVC CAS numbers, so any CAS numbers for these materials will need to be expanded to the specific substances in these materials, or a written declaration will need to be supplemented in addition to the FMD.
2019 might seem like a long way off to meet these compliance deadlines, however when you consider time it takes to create a compliance plan for RoHS3, communicate with customers as well as suppliers, and collect the data to verify compliance, the time is short.
Whether you need assistance in the above tasks or collecting written declarations of compliance and/or obtaining material declarations, GCG can help. We have been managing RoHS compliance projects since 2002, and collecting and managing written declarations and FMDs since 2003. Our Material and Substance Management software can help you to organize the data you need, run compliance reports, and serve as a defensible audit trail.