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: 8-8

RoHS Annex II Dossier, final

Indium phosphide

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1 CONTEXT and SCOPE of the DOSSIER / substance assessment

The substance assessment of indium phosphide 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 / 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 methodology which was developed as a

part of this study2.

In the course of the substance assessment, two stakeholder consultations were held to collect

information and data for the seven substances under assessment. The first one was held from 20th

April 2018 to 15th June 2018. The second one was held from 26th September to 7th November 2019

to provide specific data as to aspects on which data gaps still exist as well as to comment on the

general interpretations made as to the current base of knowledge. Records of the consultations,

including draft dossiers and stakeholder contributions, can be found at the Oeko-Institut’s project

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

For indium phosphide, the 1st stakeholder consultation yielded a total of 16 contributions 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=292.

The 12 different stakeholder contributions3 received during the 2nd stakeholder consultation, which

was held from 26th September to 7th November 2019 generally expressed their agreement to the

recommendation for not proposing InP for a restriction under RoHS. The contributions can be viewed

at http://rohs.exemptions.oeko.info/index.php?id=334.

Several stakeholders provided information on volumes of InP that are expected to be placed on the

market as part of various applications in the future. Also, an outlook on future quantum dot

technologies was provided. Several sections of the dossier have been adjusted. In particular, section

2.3 on the quantities and section 6 where several references were included concerning exposure

data with having implications on section 7, the risk evaluation, and 9, the socio-economic analysis.

Slight changes were also undertaken in 5.3 on recycling practices and 8.1 on alternatives. The input

finally led to a slightly modified Rationale in the sense of neither proposing the substance for

restriction nor for a future revision of this assessment under the same scope.

A final stakeholder meeting was held on 27 April 2020 to allow stakeholders to comment on the

dossiers and particularly on conclusions and recommendations. This document represents the final

version of the RoHS Annex II dossier for Indium phosphide.

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

3 Another six stakeholder provided the same report than already contributed by the working group of which they are

members.