RoHS2.0 Revised Directive (EU) 2015/863

On June 4, 2015, the Official Journal of the European Union (OJ) published the RoHS 2.0 amendment directive (EU) 2015/863, officially adding DEHP, BBP, DBP, and DIBP to the list of restricted substances in Annex II. As a result, Annex II now contains ten mandatory controlled substances. See the table below for details:

　　Restricted Substances Limit (mass fraction)

1. Lead (Pb) 0.1%

2. Mercury (Hg) 0.1%

3. Cadmium (Cd) 0.01%

4. Hexavalent Chromium (Cr VI) 0.1%

5. Polybrominated Biphenyls (PBB) 0.1%

6. Polybrominated Diphenyl Ethers (PBDE) 0.1%

7. Di(2-ethylhexyl) phthalate (DEHP) 0.1%

8. Phthalate Benzyl Butyl Ether (BBP) 0.1%

9. Dibutyl phthalate (DBP) 0.1%

10. Diisobutyl phthalate (DIBP) 0.1%

Following the issuance of this amendment directive, EU member states must transpose this directive into their national legislation and implement it by December 31, 2016. Moreover, as of July 22, 2019, all electronic and electrical products destined for the EU (excluding medical and monitoring equipment) must comply with these restriction requirements; as of July 22, 2021, medical and monitoring equipment (including industrial monitoring equipment) will also be included in the control scope. Additionally, toy products already subject to the restriction on phthalates under REACH Annex XVII Article 51 will not be subject to the control of DEHP, BBP, and DBP under this directive.

Note:

　　One, the implementation date for the control of the four newly added phthalates:

Considering the time required for businesses to meet the new hazardous substance requirements, Regulation (EU) 2015/863 stipulates a corresponding transition period: all electronic and electrical products (excluding equipment and monitoring instruments) must comply with the new requirements as of July 22, 2019, while equipment and monitoring instruments must comply with the new requirements as of July 22, 2021.

　　II. Interpretation of Changes to the RoHS Directive:

1. The limit requirements for DEHP, BBP, DBP, and DIBP do not apply to cables sold on the market prior to July 22, 2019, or to replacement parts for repair, reuse, functional updates, or performance upgrades of electronic and electrical equipment (EEE). Similarly, they do not apply to medical devices and monitoring equipment sold on the market before July 22, 2021.

2. Limit requirements for DEHP, BBP, and DBP do not apply to toys already subject to the restrictions under Article 51 of Annex XVII of EU Regulation No 1907/2006 (REACH).

3. The hexabromocyclododecane (HBCDD) from the previous RoHS 2.0 directive has been removed, as the European Commission believes it does not fall under the RoHS directive's regulatory scope and is already covered by the Stockholm Convention on Persistent Organic Pollutants. According to a large amount of testing data from testing agencies, phthalate esters are widely used as plasticizers in electronic and electrical products and may be present in various materials such as wires, cables, plastics, paints, and inks. Polyvinyl chloride (PVC) materials are particularly problematic as they are currently the most detected materials containing phthalates, and should be of great concern to businesses. PVC remains one of the most widely used materials in the industry, with many companies delaying improvements due to the rising cost of replacing PVC. Despite having three years to prepare for the changes under the latest RoHS directive, businesses must consider the time required for supply chain transmission and process improvements, which may lead some to shorten the timeline for limiting the use of uniform materials from suppliers. Early process improvements and seeking new eco-friendly plasticizers as substitutes will be the solution to meet the new RoHS requirements for phthalates.