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: 8-9

RoHS Annex II Dossier, final

Nickel sulphate and nickel sulfamate

8

CONTEXT and SCOPE of the DOSSIER / substance assessment

The substance assessment of nickel sulphate and nickel sulfamate 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.

According to the terms of references of the study, the scope of the assessment concerns nickel

sulphate and nickel sulfamate. For this purpose, the evaluation has compiled relevant background

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

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

information is the basis for assessing possible impacts on the environment and on health

associated with the presence of these compounds in EEE and expected to incur during the use

phase and/or during the waste phase (end-of-life). Assessment of possible impacts to arise from

the presence of other nickel compounds in EEE to be placed on the EU market is beyond the

scope of this assessment.

The specific terms of reference of the study 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.” Though an aggregation of substances in a group entry,

such as “nickel and its compounds”, appears in the regulatory context, e.g. in the context of the

scientific evaluation of occupational exposure limits, a group assessment of nickel and its

compounds was not proposed for this assessment for the following reasons:

•The nickel salts under considerations here are solely used in metal surface treatment processes,

including electrolytic plating and electroless technologies. It can be understood that these

substances are transformed through the surface treatment processes and do not remain in their

original form in the final produce, i.e. in relevant EEE and its parts. In the final coating, the nickel

salts are understood to be converted into nickel metal or nickel2+ ions, depending on the

process.

•To this extent, the assessment of “nickel and its compounds” would require an extension of the

scope of this study to additional applications of nickel and its compounds, e.g. nickel as a

derivative from surface treatment processes. This would go beyond the original scope of the

study.

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

group entry of substances, which ECHA lists on the same “Substance Infocard”.

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