Download Harriman_restrictions_Jun05.pps - Toxics Use Reduction Institute

TOXICS USE
REDUCTION
INSTITUTE
Update on Materials Restrictions
in the Global Marketplace
June 1, 2005
Wire and Cable Supply Chain Workshop
Boxborough, MA
TURI
Liz Harriman
MA Toxics Use Reduction Institute
Overview
• Materials now or potentially subject to
Restrictions
• Regulatory Materials Restrictions
– European Union
– China
• Market Drivers
– OEMs
– Labeling
• Voluntary Phase-Outs
TURI
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Materials Subject to Restrictions
• Heavy metals:
– Lead (CA Prop 65, EU RoHS, China RoHS, ELV)
– Mercury, cadmium and hexavalent chromium
(RoHS, ELV)
• Brominated flame retardants:
– PBBs (polybrominated biphenyls) (RoHS)
– Certain PBDEs (polybrominated diphenylethers)
• Penta- and Octa-BDE (EU Dangerous Substances
Directive 76/769/EEC, RoHS, U.S. voluntary agreement)
• Deca-BDE (RoHS)
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Materials Subject to Reporting or Reductions
• Halogenated materials
– PVC
• often is part of recyclability goals (e.g., Toyota)
– Brominated Compounds
• E.g., Dell goal: By 2006, reduce the amount of bromine
shipped in Dell displays by 30% from 2004
• Antimony
• TRI Reporting, on many OEM lists of reportable
substances, undergoing risk assessment in EU
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EU Regulatory Restrictions
• EU Directive 76/769/EEC: Restrictions on the
Marketing and Use of Certain Dangerous
Substances and Preparations
• EU Risk Assessments on Octa and Penta-BDE
resulted in Commission adopting risk reduction
measures:
– EU Directive 2003/11/EC (6 Feb 2003 amending
76/769/EEC) restricting octa and penta-DBE in
products, effective 15 August 2004
– Concentration limited to 0.1% by mass
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EU Regulatory Materials Restrictions
• WEEE and RoHS
– RoHS: 1 July 2006 restricts use of mercury, lead,
cadmium, hex chromium, PBBs and PBDEs
• PBBs no longer used in EU and US
– Octa and Penta BDE covered under Dangerous
Substances Directive
– Deca phase out included - exemption still uncertain
• RoHS states that EU Commission shall evaluate as a matter
of priority, whether Deca should receive exemption
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EU Deca BDE RoHS Exemption
• Human Health Risk Assessment completed with “no further risk reduction
measures required”
• Environmental Risk Assessment – final draft May 2004
– Need for further information and testing wrt PBT assessment
•
"Decabromodiphenyl ether is likely to be very persistent (vP), but not
bioaccumulative nor toxic in the marine environment according to the criteria
presented in the Technical Guidance Document. However, the PBT assessment is
complicated by data available on the:
 widespread occurrence of the substance in top predators (e.g. birds and
mammals, including terrestrial species) and the Arctic;
 neurotoxic effects and uptake of the substance by mammals in
laboratory studies; and
 possible formation of more toxic and accumulative products such as
lower brominated diphenyl ether congeners and brominated
dibenzofurans in the environment.
•
This means that the available assessment methodology might not be applicable to this
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substance."
EU RoHS & Deca BDE Risk Assessment –
Latest Breaking News….
• EC recommended exemption for decaBDE
– Member states experts committee did not back the
exemptions proposed by the EC
– Referred to council of ministers for resolution
• EU Scientific Committee on Health and Environmental Risks
(Scher) on 3/31/05 said EU risk assessment underestimated
dangers posed by deca and "strongly recommends" further risk
reduction measures
– “Emissions of deca to the environment may constitute serious problems
in the future,” with more evidence of breakdown products.
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RoHS – Implementation Considerations
• Maximum Concentration Limits
– TAC proposed 0.1% by weight (1000 ppm) of
“homogeneous materials” for Pb, Hg, Cr+6, PBB, PBDEs
– 0.01% for Cd
• Homogeneous Material
– ‘of uniform composition throughout,’ cannot be
mechanically disjointed (materials cannot be separated by
mechanical actions such as unscrewing, cutting, crushing,
grinding and abrasive processes)
– EU example: electric cable is two homogeneous materials
(the wire and the insulation)
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European WEEE
• Broad applicability to electronic products and
electrical equipment, with list of exemptions
• Objective: Divert WEEE from landfills and
incinerators to environmentally sound re-use and
recycling
• Producer responsibility, recycling at EOL, DfE recycled content of new products, RoHS
• Separation of toxic-containing components
• Plastic parts containing BFRs must be separated
prior to recovery and recycling
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WEEE/RoHS – Implementation Issues
• “placed on the market”
• Imported into EU
• Transferred to distributor or retailer
• Transferred to warehouse ready for dispatch to
customers
• “producer”
• Importer
• EU manufacturer
• Requirements will be same in all EU countries, but
enforcement and penalties may vary
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China WEEE and RoHS
• China’s Clean Production Promotion Law, effective
Jan 03 provides legislative authority for wide range of
materials restrictions in China
– CP: “fundamental reduction of pollution from sources,
enhancement of resource utilization, reduction in or
prevention of pollution during production..”
• “electronic information products” (TVs, computers,
household electronic products, instruments)
• Substances: Pb, Hg, Cd, Cr+6, PBBs, PBDEs, and
“other toxic and harmful substances”
• July 1, 2006 compliance date
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Market Supply Chain Restrictions and Drivers
• Electronics Mfr. Green Product
– Sony, Xerox, Motorola, Hitachi, and others have introduced
products and/or set goals for reducing or phasing out certain
substances
• Green labeling
– EU Flower Ecolabel prohibits:
• PBBs, PBDEs, certain chloroparaffins, for parts > 25 g in electronic
products
• Green buildings
• Take-back programs
– driver for materials that are easy and safe to recycle
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