Prioritisation of substances: Targeted approach for refined prioritisation of high priority substances

• Author: Clemm, Christan; Löw, Clara; Baron, Yifaat; Moch, Katja; Möller, Martin; Köhler, Andreas R; Gensch, Carl-Otto; Deubzer, Otmar
• Pages: 43-44

Methodology for Identification and Assessment of substances

for inclusion in Annex II under RoHS

43

2. Part II: PRIORITISATION OF SUBSTANCES: Targeted approach for refined pri-

oritisation of high priority substances

Approach: For substances / substance groups of the highest priority, additional information shall

be compiled to allow a refined prioritisation of substances in the “RoHS-Working-List” according to

the following approach.

For all substances from the highest priority groups, information shall be collected from publicly

available sources and compiled into a tabulation64 based on the template provided in the Appen-

dix, Section A.2. The tabulation should include the information for each substance regarding the

following parameters and topics:

•Substance identity (Name, CAS and EC identifiers);

•Information on the substance classifications as collected in the inventory.

•Information on uses (i.e. typical general uses and applications, and typical EEE uses and appli-

cations);

•Quantities of use (i.e. typical use volumes and EEE use volumes for the EU and/or globally,

depending on availability of information);

•First indication if the use and presence of the substance in EEE could potentially lead to im-

pacts related to Article 6(1). This should be estimated based on a short review of the most re-

cent available REACH documents (Annex XV Dossier, SEAC and RAC opinions, etc. and in re-

lation to the information available on hazards and use ad presence of the substance in EEE);

The tabulation shall be supplemented with questions for stakeholders (see template provided in

the Appendix, Section A.3). A stakeholder consultation shall be held to collect additional infor-

mation on the substances. Stakeholders shall be asked to use the excel format to provide infor-

mation for all substances subject to the refined prioritisation, though provision of additional data

and information shall also be possible. This consultation should be held according to the specifica-

tions of the EU guidelines for stakeholder consultations.65 Given that it is targeted at a limited

number of substances a shorter period may suffice, provided that the consultation does not over-

lap with common holiday periods (summer holidays, X-mas).

Grouping of substances may also be relevant at this stage e.g. in line with a simultaneous pres-

ence of substances and/or same behaviour of individual group members within the use phase or

within waste management processes. This could be the case, for example, if group members are

transformed into particular hazardous transformation or degradation products. Whether a grouping

approach is reasonable or not has to be decided on a case-by-case basis. Guidance on grouping

of substances is provided in Appendix A.6 Guidance on groups of similar substances.

It is important that, following the precautionary principle, the most hazardous group member will

be taken into consideration for the prioritisation of members of the substance group for which data

as to hazardous classification is missing (see data from P I Step 1a).

64 This format was developed in the course of a study prepared by Baron et al. (2014). An example can be viewed

here:

http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Substance_Review/Substance_Profiles/Questionaire

_Background_Info_Substances_prioritisation.xlsx.

65 The online stakeholder consultation shall be conducted following the minimum standards for consultation of interested

parties set out in the Commission Communication COM (2002) 704 final of 11.12.2002, COM(2012) 746,

COM(2012) 746, SWD(2012) 422, COM(2014) 368, and SWD(2015) 111.