Oko Institut Completes RoHS Pack 15 Substance Assessments

by Joyce Costello, Compliance & Risks

On 8 April, Oko announced completion its Substance Assessment on seven different substances and substance groups (cobalt dichloride and cobalt sulphate, nickel sulphate and nickel sulfamate, beryllium and its compounds, indium phosphide, tetrabromobisphenol-A, medium chain chlorinated paraffins, diantimony trioxide) and advised that resulting dossiers will soon be published on its website.

Oko will also hold a final stakeholder webinar on 27 April 2020 from 14 to 18 CEST, to be hosted by EU Commission DG Environment. A draft agenda is circulating in advance of the meeting, showing, as expected, that there will be discussion of the substance inventory, followed by discussion of each of the substances, for a period ranging from 15-25 minutes per substance. Before DG Environment delivers concluding remarks, Öko-Institut will give a presentation of the exemption methodology .

RoHS Pack 15 from inception to conclusion:

On 1 February 2018, EU Commission DG Environment assigned a seminal project to a consortium led by Oko Institut, to:

  1. Provide technical and scientific support for the review of the list of RoHS restricted substances;
  2. Assess a new exemption request under RoHS 2 for cadmium in luminescent material for on-chip application on LED semiconductor chips.

The project, now known as ‘Pack 15’, is mandated by Article 6 of RoHS 2 which requires that the list of restricted substances in Annex II be reviewed periodically and further sets rules for amending the list. The project was designed by the Directorate as follows:

 Part 1: Substance restriction:

‒Task 1: Update the existing methodology to identify and assess substances for possible restriction;

‒Task 2: Assess substances with a view to their possible future restriction;

‒Task 3: Determination of the quantitative usage data for substances used in EEE;

Part 2: Exemption evaluation:

‒Task 4: Exemption methodology;

‒Task 5: Exemption assessment.

The project is now concluding after over 2 years of work, and the completion of the major milestones below:

February 2018 – Pack 15 launched

April 2018 – stakeholder consultation commences on task 2 assessment of 7 substances

October 2018 – new stakeholder consultation explores the substance assessment methodology and substance inventory

September 2019 – stakeholder consultation focuses on 4 substances and a revised substance inventory

December 2019 – stakeholder comments sought on 3 remaining substances, along with data from manufacturers on 43 priority substances identified as highest priority in the inventory

January 2020 – Oko extends deadline for submission of contributions to 13 February.

Oko now hands over to the EU Commission which must decide whether or not the conditions under Article 6 have been fulfilled to enable the addition of further substances to Annex II, following which it may commence work on a draft amending Directive.