The Weekly Pulse: 1 - 5 July, 2024
Your Weekly Source for Global Regulatory Insights
This Week's Trending Sources in C2P
What are our Content Team talking about?
Phthalates to be officially in the scope of China RoHS from 1 January 2026
After a long?lead-in, China RoHS is finally being extended to cover a total of 10 restricted hazardous substances, including the?addition of 4 phthalates bis(2-ethylhexyl) phthalate (DEHP) (0,1%), butyl benzyl phthalate (BBP) (0,1%), dibutyl phthalate (DBP) (0,1%) and diisobutyl phthalate (DIBP) (0,1%) to the list?of restricted substances.?
Amendment No. 1 to GB/T 26572-2011 was published on 29 June 2024 through China National Standard Announcement No. 14.
An 18-month?transitional period will now run?until 1 January 2026, facilitating manufacturers in their preparations for the new obligations:
Interested parties are also reminded that China's National Certification and Accreditation Administration (CNCA)?announced a change in the applicable conformity assessment system testing methods under China RoHS, effective?1 March 2024.
To be consistent with international standards for testing methods of hazardous substances in electrical and electronic products, the testing method standard for the conformity assessment system for restricted use of hazardous substances in electrical and electronic products has changed from GB/T 26125 to the GB/T 39560 series of standards for the determination of substances, specifically the following 8 standards:
GB/T 39560.1?Determination of certain substances in electrical and electronic products—Part 1:Introduction and overview
GB/T 39560.2?Determination of certain substances in electrical and electronic products—Part 2: Disassembly, disjointment and mechanical sample preparation
GB/T 39560.301?Determination of certain substances in electrical and electronic products—Part 3-1: Screening lead, mercury, cadmium, total chromium and total bromine by X-ray fluorescence spectrometry
GB/T 39560.4?Determination of certain substances in electrical and electronic products—Part 4: Mercury in polymers, metals and electronics by CV-AAS, CV-AFS, ICP-OES and ICP-MS
GB/T 39560.5?Determination of certain substances in electrical and electronic products—Part 5: Cadmium, lead and chromium in polymers and electronics and cadmium and lead in metals by AAS, AFS, ICP-OES and ICP-MS
GB/T 39560.6?Determination of certain substances in electrical and electronic products—Part 6: Polybrominated biphenyls and polybrominated diphenyl ethers in polymers by gas chromatography-mass spectrometry (GC-MS)
GB/T 39560.701?Determination of certain substances in electrical and electronic products—Part 7-1: Hexavalent chromium—Presence of hexavalent chromium [Cr(VI)] in colourless and coloured corrosion-protected coatings on metals by the colourimetric method
GB/T 39560.702?Determination of certain substances in electrical and electronic products—Part 7-2: Hexavalent chromium—Determination of hexavalent chromium [Cr(Ⅵ)] in polymers and electronics by the colourimetric method
The GB/T 39560 series?corresponds?to the?IEC 62321 series?of standards.
China RoHS conformity assessment is mandatory only for electrical and electronic products listed in the first batch of the Compliance Management Catalogue and manufactured or imported after 1 November 2019. This can be done through two approaches, either voluntary certification or self-declaration, at the discretion of manufacturers/suppliers.?
Work on the development of a mandatory standard for hazardous substances restriction and labelling, effectively combining existing Standards SJ/T 11364 and GB/T 26572, is ongoing.
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What are our Knowledge Partners talking about?
Stockholm Convention Proposal to Restrict Dechlorane Plus
From Rina
Dechlorane Plus is an additive chlorinated flame retardant which has been used, according to an EU Risk Assessment in cable insulation, electrical connectors, roofing materials, wallpaper, adhesives, expanded polymer foams, latex paint, PVC? pipes, boards (solid wood, fibreboard, etc.), etc. It is also used in vehicles, medical devices, aerospace and many other applications and has been found in a wide variety of polymers including ABS, polypropylene, natural and synthetic rubbers, epoxies and PBT.?
Dechlorane Plus is a Substance of Very High Concern (SVHC) under the EU REACH Regulation and it was proposed in 2022 to be a Persistent Organic Pollutant under the Stockholm Convention(i) and it was agreed to add Dechlorane Plus to Annex A at a meeting in 2023. Global restriction is therefore likely and the EU has published draft legislation.(ii) The EU restriction will likely be the same as all other countries that are members of the Stockholm Convention and its proposed restriction is as follows:
‘Dechlorane Plus’ includes its syn-isomer and anti-isomer; CAS Numbers 13560-89-9, 135821-03-3, 135821-74-8; restricted to 1 mg/kg (0.0001 % by weight) where they are present in substances, mixtures or articles. This will apply from 26 February? 2025.?
There are several derogations where the restriction is delayed:?
? Aerospace and defence until 26 February 2030?
? Medical imaging applications until 26 February 2030?
? Radiotherapy devices and installations until 26 February 2030?
? Spare parts for (i) land-based motor vehicles; (ii) marine, garden and forestry machines; (iv) aerospace, space and defence applications; (v) medical imaging applications; (vi) radiotherapy devices and installations, where dechlorane plus was initially used in their production, until the end of their service life or until 31 December 2043.?
Dechlorane Plus appears to still be widely used globally despite it being classified as a persistent bioaccumulate toxin (PBT) so manufacturers will need to ensure that it is replaced to meet the new restriction deadlines that have been proposed in the EU.
(ii) Persistent organic pollutant - dechlorane plus (europa.eu)
What are our Clients asking about?
"Are industrial and commercial appliances in the scope of EAEU RoHS?"
Answered by Joyce Costello
EAEU RoHS applies to 11 categories of EEE, only category 1 of which refers to 'household'. I am therefore inclined to suggest that products that are used for industrial and commercial applications, other than category 1 appliances, are indeed subject to the restrictions.
Although the categories are different from the EU, there is a similar qualification on EU RoHS categories 1, 2 and 4 as applying to household appliances and consumer equipment, respectively. Otherwise, the situation is that industrial appliances are in scope, as regards the other categories.
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