Identification of substances

• Author: Clemm, Christan; Löw, Clara; Baron, Yifaat; Moch, Katja; Möller, Martin; Köhler, Andreas R; Gensch, Carl-Otto; Deubzer, Otmar
• Pages: 23-42

Methodology for Identification and Assessment of substances

for inclusion in Annex II under RoHS

23

1. Part I IDENTIFICATION OF SUBSTANCES

The aim of Part I is to identify all substances in EEE, which may cause risks for the environment

during use16 or risks for the environment and workers during WEEE management or have any

other negative impacts during waste management, as specified by RoHS 2, Article 6.

Article 6(1) requires taking special account of whether a substance, including substances of very

small size, or with a very small internal or surface structure, or a group of similar substances:

a) “could have a negative impact during EEE waste management operations, including on the

possibilities for preparing for the reuse of waste EEE or for recycling of materials from waste

EEE;

b) could give rise, given its uses, to uncontrolled or diffuse release into the environment of the

substance, or could give rise to hazardous residues, or transformation or degradation prod-

ucts through the preparation for reuse, recycling or other treatment of materials from waste

EEE under current operational conditions;

c) could lead to unacceptable exposure of workers involved in the waste EEE collection or

treatment processes;

d) could be replaced by substitutes or alternative technologies which have less negative im-

pacts.”

Approach: The standardised methodology as described below shall allow for a stepwise proce-

dure for assessing substances for possible future restriction under RoHS in order to fulfil the over-

all goal of protecting human health and the environment from negative impacts related to use or to

WEEE management.

The identification of potentially RoHS-relevant substances used in EEE involves three major tasks:

•Creation of an inventory of substances (P I Step 1):

挑 Updating information on substances classified or suspected as hazardous (P I Step 1a);

挑 Updating information on substances used and/or present17 in EEE (P I Step 1b);

•Pre-assessment of priority of substances listed in the inventory (P I Step 2):

挑 First run of the pre-assessment to establish classification of substances to priority groups (P I

Step 2a);

挑 Stakeholder consultation for collecting information on substances in the inventory with focus

on the substances in the highest priorities (P I Step 2b);

•Update information in the inventory and re-run pre-assessment to conclude on substances in

highest priorities18 to be subject refined prioritisation in P II (P I Step 3).

16 Article 6(1)(b) provides inter alia the basis for restricting a substance, should its uses give rise to uncontrolled or

diffuse release into the environment of the substance. This is understood to refer to possible releases related to the

intended use of a substance but also to non-intended use, for example in the case of breakage.

17 Substances used in manufacture of EEE may or may not be present in the final product. Similarly, substances pre-

sent in EEE may or may not have been applied in this form in the manufacture. The inventory shall update infor-

mation on substances used in manufacture and on substances present in EEE, specifying presence where this data

is found to allow a differentiation at later stages.

18 The number of substance (priority classes) to be subjected to the prioritisation of P II shall be discussed and ap-

proved with the EC, also depending on the study framework.

Methodology for Identification and Assessment

of substances for inclusion in Annex II under RoHS

24

Figure 1-1 below provides an overview of how to identify these substances and illustrates the flow

of decisions.

Figure

1-1:

Workflow of identifying substances used in EEE with a potential negative

impact during use, and/or on or during waste management

Source:

Adapted with revisions from AUBA (2013)

An inventory of substances used in EEE was established during the first review of Annex II of

RoHS in 2013-2014. The inventory established in 2013 AUBA provides a first basis to be updated

in the following periodic reviews. Each further revision should use the initial inventory of the last

revision as a first basis to be updated, adding and updating existing data before applying the vari-

ous selection and prioritisation stages. For establishing the 2013 inventory, two main sources of

information were used:

•Existing databases on substances where information is gathered and presented on the use of

substances in products:

挑 IEC 62474 database on material declaration

挑 ZVEI-Umbrella specifications

挑 ECHA-registered substances with the use descriptor “SU 16: Manufacture of computer, elec-

tronic and optical products, electrical equipment”