The number of substances that are being added to the list of restricted substances (Annex II) of the EU Directive 2011/65/EU (RoHS 2) is set to grow. Knowing the process through which substances are being selected for inclusion on “The List” can prove important when trying to choose the right type of product chemistry in the product development phase. Furthermore, it can also help manufacturers to better communicate to customers the efforts they undertake to ensure the safety and sustainability of their Electrical & Electronic Equipment (EEE). Here’s a glimpse at how the substance selection process works.

Recital 10 (or preliminary statement 10) of the EU Directive 2011/65/EU (RoHS 2) identifies the use of several substances as a priority for a first substance review process. It also requires the completion of the review by 22 July 2014.

Furthermore, the substances in question need to be reviewed periodically thereafter by the European Commission, either of its own initiative or following the request of a Member State. These substances are:

  • Hexabromocyclododecane (HBCDD) a brominated flame retardant
  • Bis (2-ethylhexyl) phthalate (DEHP) a commonly used plasticiser
  • Butyl benzyl phthalate (BPP) a commonly used plasticiser
  • Dibutyl phthalate (DBP) a commonly used plasticizer

The Selection Method

A Methodology Manual prepared by the Environment Agency of Austria, at the request of the European Commission, provides a documented methodology to support decisions about the inclusion of substances in ANNEX II of RoHS, based on scientific evidence and research data sourced from the REACH scientific committees.

The Methodology Manual underlines the relationship between RoHS and REACH and quotes Recital 16 of RoHS that indicates that information generated by REACH should be used when implementing regulations that cover Electrical & Electronic products. For more details on the RoHS – REACH relation read our Safeguards No 009/14 .


The Methodology Manual is divided in three major sections:

Part I

Identification of Substances – covers the identification of substances used in EEE, which may have negative impacts on human health, the environment or the efficient management of WEEE (Waste Electrical and Electronic Equipment).

Part II

Pre-Assessment of Substances – covering the prioritization of substances used in EEE, which may most likely have negative impacts on human health, the environment or the efficient management of WEEE.

Part III

Detailed Assessment of Substances – covers the in-depth analysis of high priority substances that may lead to their restriction under RoHS 2.

Priority Substances Identified

The application of the Methodology Manual has already resulted in the identification of various substances and their relevant level of priority. In addition to the four first priority substances mentioned above, additional substances have been identified and could be added to the list of restricted substances in the future. Click here to access the complete 2nd Interim Report. The substances and their four levels of priority are:

Priority I Substances

Eleven substances have been identified as fulfilling all 3 waste criteria and the hazard properties (human health & environment) to warrant their classification as priority I substances. These are:

Phthalate plasticizers:

  • Bis (2-ethylhexyl) phthalate (DEHP)
  • Butyl benzyl phthalate (BBP)
  • Dibutyl phthalate (DBP)
  • Diisobutylphtalate (DIBP)

Halogenated flame-retardants:

  • Hexabromocyclododecane
  • Dibromo-neopentyl-glycol
  • Dibromo-propanol
  • SCCP (short chained chlorinated paraffins), C10-13

Other halogenated compounds:

  • 1,2-dibromoethane
  • tris(2-chloroethyl)phosphate
  • Hexachlorobenzene (already listed in the Stockholm Convention

Priority II Substances

There are four substances that currently fulfill all 3 waste criteria and the hazard properties (human health & environment) relevant for the priority group II:

  • 1Diethyl phthalate (DEP)
  • MCCP (medium chained chlorinated paraffins), C14 – C17 Antimontrioxid
  • Tetrabromobisphenol A”

Priority III Substances

Only one substance has been included in this priority category. That substance is: Polyvinylchloride

Priority IV Substances

Five substances have been identified as belonging to the overall priority category IV:

  • Nickel sulfate
  • Nickel bis(sulfamidate); Nickel sulfamate
  • Beryllium metal
  • Beryllium oxide (BeO)
  • Indium phosphide

First Set Of Substances Evaluated

A first set of public consultations has been performed, in order to perform an evaluation of the first set of substances: HBCDD, DEHP, BBP and DBP to be potentially included in RoHS 2, Annex II. Currently stakeholders have been invited to contribute to the evaluation process.

The results will be published in a final report on the methodology developed for identification and assessment of substances.

The final conclusion of the identification and assessment process, and the draft recommendations for inclusion of substances in the RoHS2 list of restricted substances will be presented soon.

Substances Knowledge Is Key

Being on top of the list of substances currently restricted under RoHS 2 or those that are being evaluated for restriction is essential. It is also equally important to understand the process used to identify and prioritize substances for RoHS. This allows manufacturers and suppliers to proactively move towards an alternative substance assessment for their EEE and components.

Support with tackling the complex aspects of global hazardous substances regulations is available. Thanks to its industry expertise and global network of accredited labs, SGS is ideally positioned to support manufacturers, importers and retailers with technical assistance, process assessment, chemical and materials testing, and consulting services for RoHS, REACH or other emerging chemical regulations.

For more information on our services please visit: www.sgs.com/rohs or contact:

Kenneth Stanvick
Environmental Compliance Management
Senior Consultant
Electrical and Electronics
SGS North America Inc.
t: +1 603 305 4103