Product Environmental Regulations

If you are involved in manufacturing or selling electronics, it is crucial to stay up to date with the world’s constantly evolving product environmental regulations. This article will present an overview of future regulations regarding PFAS, EU RoHS, REACH, and Prop. 65 substances.

PFAS Product Environmental Restrictions

PFAS, short for per- and polyfluoroalkyl substances, have attracted attention due to their remarkable durability, earning them the moniker “forever chemicals”. Currently, the European Chemicals Agency (ECHA) only regulates a handful of PFAS groups. Included are PFOS and PFOA, which fall under the scope of REACH and POP regulations.

However, change may be on the horizon. On February 7, 2023, the ECHA proposed a new PFAS regulation that may restrict approximately 10,000 groups of PFAS. If implemented, the proposed restriction would prohibit the use of PFAS in articles, mixtures, and substances (exceeding a certain threshold). The restriction would include an 18-month transition period, and some sectors – like biocides and medicine – could be allowed to bypass the restrictions for another five or twelve years after the transition period ends. Currently, the ECHA is undergoing a six-month consultation period to determine the merit of this proposal.

EU RoHS – New Electronic Product Environmental Restrictions

EU RoHS is one of the most important regulations for those working in electronics. It applies to most Electric and Electronic Equipment (EEE) and currently restricts the following ten substances:

Lead
Cadmium
Mercury
Hexavalent chromium
Polybrominated biphenyls (PBB)
Polybrominated diphenyl ethers (PBDE)
Bis(2-ethylhexyl) phthalate (DEHP)
Butyl benzyl phthalate (BBP)
Dibutyl phthalate (DBP)
Diisobutyl phthalate (DIBP).

The Oeko-Institute has proposed the addition of two new substances, tetrabromobisphenol A (TBBPA) and medium-chain chlorinated paraffins (MCCPs), which would bring the total number of RoHS substances to 12.

TBBPA and MCCPs are often used as flame retardants and additives in various products. TBBPA is a brominated flame retardant used in plastics and resins, while MCCPs serve as flame retardants, plasticizers, and lubricants in metal products. These substances may cause environmental and health hazards – including endocrine disruption and neurotoxicity – which likely prompted their addition to the RoHS list. If the revision is approved, TBBPA and MCCPs could be added to the list as early as 2024, with enforcement starting in 2027.

EU REACH – More SVHCs

The European Commission (EC) has proposed the addition of two substances to its list of SVHCs. SVHCs are chemicals that pose a risk to people and the environment, and REACH regulations require companies to declare them if they are present in products above 0.1% by weight. Every six months, the EC adds new SVHCs to the list.

Prop. 65 – New Substances

Proposition 65, also known as Prop. 65, applies to all consumer goods sold in California and businesses with ten or more employees. If a substance exceeds its No Significant Risk Level (NSRL) or the Maximum Allowable Dose Levels (MADL), the vendor must declare the chemical on a warning label. There are approximately 900 Prop. 65 chemicals to date, and the OEHHA may add two more: 1,1,1-Trichloroethane and Leucomalachite Green.

1,1,1-Trichloroethane, also known as methyl chloroform, is an ozone-depleting substance commonly used to clean electronic parts and as a solvent. Its addition to the Prop. 65 list is due to its effects as a nervous system depressant and its potential to cause ethanol intoxication.

Leucomalachite Green is a dye typically used in various materials, such as leather, paper, and silk. It has a Group 2B carcinogen classification, indicating that it’s “possibly carcinogenic to humans.”

Every year, new Prop. 65 susbtances appear on the list.

Staying up to date with environmental compliance regulations is crucial for businesses. With upcoming changes to PFAS, RoHS, REACH, and Prop. 65 regulations, manufacturers must be vigilant to ensure they meet the new requirements.