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: 35-35

RoHS Annex II Dossier, final

Nickel sulphate a nd nickel sulfamate

35

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

The two nickel salts nickel sulphate and nickel sulfamate are 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 product, i.e. in relevant EEE and its parts. In the final coating, the

nickel salts are understood to be converted into nickel metal. It is therefore expected that a

restriction of these compounds in EEE would not necessarily be effective in preventing their use in

the processes. It is therefore not recommended to restrict the two substances, as benefits on

health and environment would not be expected to incur as a result of such a restriction.

In parallel, the assessment would recommend a future assessment under RoHS of nickel and its

compounds in order to clarify the range of expected impacts of nickel metal and nickel2+ ions

during use and/or waste management to clarify the range and nature of possible impacts related to

the presence of Ni and its compounds in EEE in the use and waste phases and whether a RoHS

restriction of this group would allow preventing such impacts.51

It should be noted in this regard that the Swedish Chemical Agency KEMI (2015)52 in its

assessment of the risk reduction potential of hazardous substances in electrical and electronic

equipment on the EU market concluded that nickel sulphate and nickel sulfamate as process

chemicals for electroplating are not relevant for inclusion in RoHS. It should further be noted that

during the substance prioritisation that is also performed in one task of this project, nickel and

nickel monoxide have been included in the shortlisted substances.53 The outcome of the substance

prioritisation was based on the application of an algorithm to the substances in the EEE Inventory

and the inclusion of nickel and nickel monoxide in the shortlist does not presume a

recommendation for the inclusion in Annex II of the RoHS Directive. From the background that

nickel, nickel alloys and various individual Ni compounds occur at different life cycle stages of EEE

and pose different hazards, is recommended to undertake an aggregated assessment of the whole

group entry “nickel and its compounds”, rather than specific Ni salts (scope of the current service

request).

51 The Nickel Institute (2019) stated on this paragraph that “this conclusive statement is not supported by any evidence

in the draft Report. In addition, it should be acknowledged clearly that nickel metal has a different and lower hazard

classification than nickel compounds. This aspect is not mentioned anywhere in the draft Report. It is an important

point which should be acknowledged.” The addition on the different hazard classification are made in section 3.

52 Opt cit. Swedish Chemicals Agency KEMI (2015)

53 The entry of nickel and its compounds in REACH Annex XVII based on the classification as skin sensitizer is one

reason for this inclusion.