EU Plans to Launch Public Consultation on Amendment to RoHS Directive by Adding TBBP-A and MCCPs Content Requirement on Electrical and Electronic Equipment (EEE)
In May 2022, the European Commission has published notification on official website regarding a plan to launch public consultation on amending Annex II to RoHS Directive 2011/65/EU. The content requirements on the substances tetrabromobisphenol A (TBBP-A, CAS No. 79-94-7) and medium-chain chlorinated paraffins (MCCPs, CAS No. 85535-85-9) will be proposed to be newly added in Annex II to RoHS Directive 2011/65/EU on restricted substances.
The adoption is planned in the fourth quarter of 2022.
In March 2021, the technical and scientific assessment organisation for EU RoHS Directive, Oeko-Institut e.V. has published the final report on study to support the review of the list of restricted substances under RoHS 2 (Pack 15). The recommended restricted limits are 0.1% per weight for TBBP-A and MCCPs in homogeneous materials of Electrical and Electronic Equipment (EEE), respectively:
| Recommended Restricted Substances |
Recommended Limits |
Recommended Exemptions |
TBBP-A
(Additive application of 2,2',6,6'-tetrabromo-4,4'-isopropylidenediphenol or tetrabromobis-phenol A)
EC No. 201-236-9
CAS No. 79-94-7 |
0.1% per weight |
Reactive TBBP-A applications and in particular its use as a component of FR4 PWB (printed wiring boards) |
MCCPs
(Chlorinated paraffins containing paraffins with a chain length of C14-17, linear or branched)
EC No. 287-477-0
CAS No. 85535-85-9 |
0.1% per weight |
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The primary use of TBBP-A is as a precursor in the production of brominated epoxy resins that function as reactively flame-retarded substrate in printed wiring boards (PWB). It is also used as an additive flame retardant in thermoplastic EEE components, for example housings that consist of ABS plastic.
The potential endocrine disrupting properties of the substance TBBP-A may lead to an adverse effect to the workers of EEE waste processing plants that expose to the substance. The substance may be able to continuously release into and accumulate in the environment. The substance TBBP-A is classified to have very high acute and chronic toxic effects to aquatic life, according to CLP Regulation (EC) No 1272/2008.
The main function of MCCPs is that of a secondary plasticiser (extender) in PVC. Moreover, MCCPs provide flame retardant properties that are harnessed on top of its function as a plasticiser extender. MCCPs are used as such in PVC, rubber and other polymers, including polyurethane, polysulphide, acrylic and butyl sealants and adhesives. MCCPs were used as a substitute for short-chain chlorinated paraffins (SCCPs) in applications such as rubber and sealants.
MCCPs are classified to be reprotoxic via lactation of breast-fed children, and to have very high acute and chronic toxic effects to aquatic life, according to CLP Regulation (EC) No 1272/2008. MCCPs have also been assessed of being very persistent and very bioaccumulative (vPvB) and persistent, bioaccumulative and toxic (PBT).
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