Rationale for inclusion of the substance in annex II of rohs

• Author: Clemm, Christan; Löw, Clara; Baron, Yifaat; Moch, Katja; Möller, Martin; Köhler, Andreas R; Gensch, Carl-Otto; Deubzer, Otmar
• Pages: 33-33

RoHS Annex II Dossier, final

Five cobalt salts

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9.5. Impact on waste management

As the compounds do not remain present in the final product, it is assumed that manufacture could

continue without change and thus also the placing on the market of relevant products. The same

EEE would reach the waste phase and require treatment and in this sense, any possible impacts at

this stage related to the use of the five compounds in plating processes would not be expected to

differ.

9.6. Impact on administration

As a restriction is not expected to affect EEE placed on the market, such ineffective listing of

substances under RoHS should be avoided because compliance with the restriction would require

provision of documentation and in some cases testing. This would result in an administrative

burden for manufacturers and suppliers, and it can also be expected that a certain administrative

burden would fall on regulators in relation to the implementation of the restriction in the RoHS

Directive and in national legislation and its enforcement.

9.7. Total socio-economic impact

To summarise, a possible restriction can be expected to result in administrative costs for both,

industry (e.g. EEE manufacturers, suppliers) and for regulators (e.g. legislators, market

surveillance). However, the restriction is not expected to generate benefits for the environment or

for health (in the form of prevention of possible impacts tied with the five cobalt salts in general and

particularly during the use and waste phase of interest for RoHS 2 Article 6(1)). In terms of total

socio-economic impacts this suggests that a restriction of the five substances would not be

proportionate, given that its costs are not expected to generate benefits for the environment or for

health.

10. RATIONALE FOR INCLUSION OF THE SUBSTANCE IN ANNEX II OF ROHS

The five cobalt salts cobalt sulphate, cobalt dichloride, cobalt dinitrate, cobalt carbonate, and cobalt

diacetate are used in metal surface treatment processes, including electroplating and metal

passivation. It can be understood that these substances are converted 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 cobalt salts are understood to be converted into metallic

cobalt, as an alloyed metal layer, or as a metal oxide/hydroxide complex, or as another cobalt-

containing compound.

Therefore, it is not recommended to include the five cobalt salts under consideration in this

substance assessment to the list of restricted substances under RoHS. The reaction products are

coatings or layers of cobalt metal or a cobalt-containing compound (alloy) or cobalt oxide/hydroxide

complex. Thus, the cobalt salts are not present in the original form in the final EEE.