Restrictions on MCCPs and TBBP-A Recommended Under EU RoHS Regulation

EU RoHS Consultation Project Pack 15 under EU Directive 2011/65/EU (ROHS
2) concluded on April 27, 2020, with the recommendation to restrict medium
chained chlorinated paraffins (MCCPs) and tetrabromobisphenol-A (TBBP-A).

Consultation project Pack 15 began in December 2017 and contained two
main parts:

  1. Review the existing methodology for identifying and assessing substances for possible restriction and updating the substance inventory
  2. Assess several
    substances for possible restriction, these were:
    • Cobalt dichloride and cobalt sulphate
    • Nickel sulphate and nickel sulfamate
    • Beryllium and its compounds
    • Indium phosphide
    • TBBP-A
    • MCCPs
    • Diantimony trioxide

Closure of the Substance Assessment on these substances was announced on
April 8 by the EU RoHS consultation agency, with the technical dossiers being
published soon afterward. The final results were presented and discussed at the
meeting on April 27, 2020, held via web conference. The virtual nature of the
meeting meant discussion was limited and so stakeholders were given an extra
week to comment in writing, although no further revision cycle is foreseen.

While restrictions were recommended for MCCPs and TBBP-A, no restriction
recommendations under RoHS were made for the other five substances.

The recommends for restriction are:

  • MCCPs with a chain length of C14-17 – linear or branched. These fulfil the criteria in REACH Annex XIII for persistent, bioaccumulative and toxic (PBT) and very persistent and very bioaccumulative (vPvB). The recommended limit of MCCPs is not communicated, due to the global differences in the nomenclature and Chemical Abstract Service (CAS) numbers used in various regions, the restriction on MCCPs is based on chlorine content in relation to a chain length within a certain range instead of referencing CAS numbers.
  • TBBP-A regulated limit is suggested as 0.1% (mass fraction). This substance is currently under review as an endocrine disruptor and PBT under
    REACH

Alternatives to MCCPs, as both a plasticizer and flame retardant, are
already commercially available.

SGS RoHS Services

Through a global network of laboratories and our requirements experts, SGS
offers advisory services on requirements and compliance solutions to support
companies affected by this Directive, be it for their conformity assessment or
risk management in the supply chain. SGS offers RoHS testing services in
laboratories accredited for the international standards applicable to these
requirements and SGS RoHS Certification which is a voluntary product
certification scheme.
Learn more about SGS’s RoHS Services.

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For further information contact:

Ethan Zhang
Technical Supervisor, EET RSTS
Tel: (86) 574 8776 7006 ext. 6007

Email: crs.media@sgs.com

Website: www.sgs.com/ee

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