Context and scope of the dossier/substance assessment

• Author: Clemm, Christan; Löw, Clara; Baron, Yifaat; Moch, Katja; Möller, Martin; Köhler, Andreas R; Gensch, Carl-Otto; Deubzer, Otmar
• Pages: 7-8

RoHS Annex II Dossier, final

Five cobalt salts

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CONTEXT and SCOPE of the DOSSIER / substance assessment

This substance assessment of cobalt salts is being performed as part of the “Study on the review

of the list of restricted substances and to assess a new exemption request under RoHS 2 – Pack

15”. With contract No. 07.0201/2017/772070/ENV.B.3 implementing Framework Contract No.

ENV.A.2/FRA/2015/0008, a consortium led by Oeko-Institut for Applied Ecology, has been

assigned by DG Environment of the European Commission to provide technical and scientific

support for the review of the list of restricted substances and to assess a new exemption request

under RoHS 2. This study includes an assessment of seven substances and group of substances1

with a view to the review and amendment of the RoHS Annex II list of restricted substances. The

seven substances have been pre-determined by the Commission for this task. The detailed

assessment is being carried out for each of the seven substances in line with a uniform

methodology2.

According to the terms of references of the study the scope of the assessment concerns cobalt

dichloride and cobalt sulphate. For this purpose, the evaluation has compiled relevant background

information for understanding whether the two cobalt compounds are used in the manufacture of

EEE and whether they remain present in final EEE articles placed on the EU market. However, the

terms of reference of the study further points out that the “grouping of substances (e.g. for cobalt or

nickel compounds or for MCCPs) shall be possible by following the approach determined in the

updated methodology, once agreed.” In the course of the assessment, it became apparent that the

European Chemicals Agency (ECHA) was considering a restriction on the manufacturing, placing

on the market and use of five cobalt salts as substances on their own or in mixtures. These five

cobalt salts are: cobalt dichloride and cobalt sulphate together with cobalt dinitrate, cobalt

carbonate and cobalt di(acetate). Therefore, it was recommended to the European Commission to

extend the scope of this assessment under the RoHS Directive to the five cobalt salts as proposed

by ECHA for a REACH Annex XVII restriction. The European Commission agreed in January 2019

to this scope adjustment. It should be noted that this adjustment was proposed because it was only

possible to gather aggregated information with regards to EEE for the five cobalt salts, and not only

for the two cobalt salts as initially foreseen.

However, further cobalt compounds including cobalt metal and cobalt alloys are not considered in

this dossier. Their impact on human health and the environment during use or in the waste phase

will not be assessed.

In the course of the substance assessment under RoHS, a 1st stakeholder consultation was held

from 20 April 2018 to 15 June 2018 to collect information and data for the seven substances under

assessment. Information on this consultation can be found at the Oeko-Institut’s project webpage

at: http://rohs.exemptions.oeko.info/index.php?id=289.

This consultation - as held before the scope adjustment - focused solely on cobalt dichloride and

cobalt sulphate. For cobalt dichloride and cobalt sulphate, a total of seven contributions were

1 For the sake of better readability hereafter the term substance will be used for single substances as well as for group

of substances.

2 This methodology includes a dossier template for substance assessment which had been prepared by the Austrian

Umweltbundesamt GmbH in the course of a previous study. The methodology for substance assessment has been

revised based on various proposals from and discussions with stakeholders. Among others, revisions have been

made to clarify when the Article 6(1) criteria are considered to be fulfilled and how the precautionary principle is to be

applied. The methodology has also been updated in relation to coherence to REACH and other legislation and

publicly available sources of relevance for the collection of information on substances have been updated and added.

The methodology is available at https://rohs.exemptions.oeko.info/index.php?id=341