22 Sept 2017
Electronics Fall under Spotlight in Sweden in New Consultation on Certain Hazardous Substances
On 15 September 2017, the Swedish Chemicals Agency (SCA) concluded a stakeholder consultation on the potential for substitution of medium-chained chlorinated paraffins (MCCPs) in electric and electronic equipment (EEE). The consultation follows the template for amendments to the European Restriction of Hazardous Substances (RoHS2) directive. Should the SCA decide to proceed with a restriction of MCCPs, the consultation as well as the SCA’s own report will serve as the basis of such an amendment. However, the report itself does not reach any definitive conclusion on whether restriction is desirable.
MCCPs are a group of organic substances containing varying amounts of chlorine. The group of substances is classified as hazardous under the EU’s Classification, Labelling and Packaging (CLP) Regulation and is highly toxic to aquatic organisms, while studies have also shown that the group may have endocrine disrupting properties. According to the SCA report, its use may therefore pose a risk to the environment as well as to human health. To date, however, use of MCCPs is not explicitly restricted under any EU legislation.
The main use of MCCPs in EEE is as secondary plasticisers and flame retardants in flexible PVC used as sheathing and insulation jackets for cables and wires. PVC sheathed cables and wires are used in the majority of household electrical and electronic appliances. The SCA noted that the various treatment processes for MCCP-containing waste may involve risks for workers (e.g. during the shredding of PVC cable waste if no respiratory protection equipment or gloves are used) as well as to the environment (e.g. landfilling of waste of EEE).
According to the SCA, potential alternatives to MCCP in EEE are long-chained chlorinated paraffins (LCCPs) and other plasticisers. It noted, however, that it is unlikely that a single substance can substitute MCCPs across all its uses, given the material’s function both as a plasticizer and as a flame retardant. The SCA held that, although phthalates such as DINP and DIDP are PVC plasticisers that have technical advantages compared to MCCPs and have long been used by the market, they lack the flame retarding effects of MCCPs and are also more expensive. This was in line with the conclusions reached by the Danish EPA in a report from 2014. The SCA nevertheless concluded that MCCPs are substitutable, but that alternatives would probably have to be introduced on a product-by-product basis.
As mentioned, the SCA did not reach a firm conclusion in its report on whether MCCPs should be restricted under the RoSH2 Directive. Yet it noted that a restriction on its use in EEE would result in a significant reduction in overall MCCP usage. This would greatly reduce the amount of MCCPs released during EEE waste management and the accompanying risks to human health and the environment.
In its public consultation, the SCA queried stakeholders for further information on what the costs and qualitative differences would be of using MCCP alternatives; the environmental impact of current MCCP usage; and other advantages and disadvantages which would flow from substitution. Depending on the outcome, the SCA will decide whether or not to proceed and suggest a restriction of MCCPs as part of the RoSH2 at the EU level.