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- From: "IPCmail" <IPCmail@xxxxxxx>
- To: "IPCmail" <IPCmail@xxxxxxx>
- Date: Wed, 14 May 2008 10:42:46 -0400
Dear IPC members:
The öko Institute was retained by the EU Commission to study the inclusion of
additional substance restrictions in the RoHS Directive. One of the substances
identified is Tetrabromobisphenol A (TBBPA), the flame retardant used to
protect more than 80 percent of printed circuit boards and found to be safe by
a comprehensive European Union Risk Assessment. In addition to TBBPA, the
Institute suggests banning Hexabromocylcododecanes (HBCDD), several phthalate
plasticizers, and all organic compounds containing chlorine and bromine.
The Institute held a workshop on 6 May to review and discuss the draft report
<http://files.ipc.org/RoHSOkoReport.pdf> (overviewed in
http://files.ipc.org/RoHSOkoPPT.ppt). The draft report relies upon biased and
flawed methodology, which is discussed further below. Despite our substantial
technical expertise and obvious interest as the representative of significant
stakeholders in any RoHS expansion, IPC was denied permission to attend this
meeting. The Institute staff actually suggested that only "scientific experts
were invited" to the workshop and that the meeting room was at capacity. We are
very concerned that the Institute did not make a serious effort to involve all
stakeholders.
IPC believes the potential expansion of RoHS is of vital importance to the
electronics industry. While we have already sent a letter
<http://files.ipc.org/IPCOkoLetter.pdf> to the commission alerting them to the
circumstances under which the Institute's report was prepared, we do not
believe this is enough. We therefore plan to schedule a meeting in Brussels on
18 June 2008 to include all interested stakeholders. We plan to invite the EU
commissioners and staff to this meeting so they can directly hear your concerns
regarding the potential expansion of RoHS. This meeting will only be successful
if we gather a substantial number of technical experts from our member
companies who can explain to commission staff the issues concerning the
Institute's incomplete and flawed report.
So that we can plan for an adequate sized facility, please let us know by
Tuesday, 20 May if we can expect you or another member of your company to
attend and participate in this important meeting or if you would like to
otherwise support this effort. Please use this link
<http://www.surveymonkey.com/s.aspx?sm=Q4xsH8YdzkDbfHy29vV_2bkQ_3d_3d> to
respond. Please feel free to forward this notice to anyone you feel should
attend this meeting.
If you have any questions, please contact Fern Abrams at +1 703-522-0225 or by
e-mail at fabrams@xxxxxxxx
Background Information on the öko Report
The Öko Institut report <http://files.ipc.org/RoHSOkoReport.pdf> proposes
adding the following substances to the list of those prohibited under RoHS:
* Tetrabromobisphenol A (TBBPA) - reactive use of TBBPA might be
exempted, but this would be only a temporary exemption that would be reviewed
every four years.
* Hexabromocyclododecane (HBCDD)
* Bis (2-ethylhexyl) phthalate (DEHP)
* Butylbenzylphthalate (BBP)
* Dibutylphthalate (DBP)
* Medium-chained chlorinated paraffins (MCCP) (Alkanes, C14-17, chloro)
* Short-chained chlorinated paraffins (SCCP) (Alkanes, C10-13, chloro)
* Nonylphenol/Nonylphenol ethoxylates
* Organochlorine and organobromine compounds
The report details data collection methods (Chapter 1); selection criteria
(Chapter 2); a discussion of the substances recommended for prohibition under
RoHS (Chapters 3 and 4), possible substitutes (Chapter 5), and policy options
(Chapter 6).
Concerns about the report and its methodology
Instead of limiting themselves to the criteria provided by the EU Commission,
the öko Institute created new criteria and categories for inclusion, including
observance in the environment and concerns about combustion. Without the
creation of these additional criteria, TBBPA and the catch-all chlorinated and
brominated organic compounds, which do not meet the report's criteria of
substances of high concern, might not have been included. The selection of
substances based on the criterion of being found in the environment is very
broad and did not follow a scientific approach. If applied consistently, this
approach would result in the listing of thousands of substances simply because
they can be detected in the environment.
There is a complete lack of scientific evidence supporting this broad category
of chlorinated and brominated organic compounds other than references to
concerns about incomplete combustion. In addition to the technical hurdles
posed by the elimination of this broad category of substances, testing for all
chlorinated and brominated organics would be prohibitively expensive for both
manufacturers and authorities.
Substitution of plasticizers and the possibility to ban PVC is also proposed,
with only two phosphate plasticizers discussed as possible substitutes in the
report.
The Institute also ignored the ongoing objectives of unifying European
Chemicals regulation through REACH because of their concern that there was a
need for a more focused legislation on electronic and electrical equipment.
There is significant concern among industry that the ongoing expansion of RoHS
will be largely inconsistent with the implementation of REACH, which is meant
to be an overarching policy.
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