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: 10-11

RoHS Annex II Dossier, final

Diantimony trioxide (flame retardant)

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CONTEXT and SCOPE of the DOSSIER/ substance assessment

The substance assessment of diantimony trioxide 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.

In the course of the substance assessment, 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 Oeko-Institut’s project webpage at:

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

For diantimony trioxide, a total of 14 contributions were submitted by different stakeholders. An

overview of the contributions submitted during this consultation is provided in Appendix I. The

contributions can be viewed at: http://rohs.exemptions.oeko.info/index.php?id=290.

Based on stakeholder input and publicly available information, a second version of the dossier has

been prepared, which was subject to a 2nd stakeholder consultation that was held from 05 December

2019 to 30 January 2020. The consultation period was prolonged for two weeks in order to

compensate for any cooperation difficulties that might have arisen due to the holiday season and

ended on 13 February 2020.

For diantimony trioxide, a total of 18 contributions were submitted by different stakeholders. An

overview of the contributions submitted during this consultation is provided in Appendix I. The

contributions can be viewed at: https://rohs.exemptions.oeko.info/index.php?id=332.

Additionally, there were confidential contributions submitted that contain concrete socio-economic

information and cost estimates. As no restriction of ATO is proposed, it was decided not to process

these data further.

Stakeholders mainly commented in the 2nd stakeholder consultation on the following issues:

• Uses and quantities, variety of formulations to achieve flame retardancy;

• Waste management and sorting techniques,

• The references on exposure data and the estimation of risks for workers,

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