Updates from TTI MarketEye on the Stockholm Convention on POPs and SCIP Database Pollution
By Michael Kirschner
I’ve mentioned the Stockholm Convention in the past, but maybe not often enough. As I noted then, the Convention “is a global treaty to protect human health and the environment from POPs (persistent organic pollutants). POPs are chemicals that can remain intact in the environment for long period of time, can be widely distributed geographically, accumulate in the fatty tissues of humans and wildlife, and have harmful impacts on human health or the environment.” Most markets, notably not including the U.S., have ratified the Convention and implemented it in their local regulatory regimen.
The Stockholm Convention is the source of international bans of several substances – particularly halogenated flame retardants – historically used in electronics, including hexabromobiphenyl, hexabromocyclododecane, short-chain chlorinated paraffins and – recently – decabromodiphenyl ether (DecaBDE). These bans are reflected in regulations like the EU POPs Regulation, Canada’s Prohibition of Certain Toxic Substances Regulation and others.
Some manufacturers request information on compliance with it, but most in the electronics industry supply chain, from brand owners and OEMs to component and even material manufacturers, seem unaware of it. Ignoring it results in what are ultimately unnecessary business and environmental/human health risks.
In fact, I have been engaged for months with a major passive component manufacturer regarding the presence of hexabromobiphenyl in their online full material declaration information for a particular component. The document itself is over a decade old, which alone is problematic. Is the product unchanged or have they forgotten to review and update it? How hard is it to put a recent date on an old document if nothing has changed?
Manufacturers must have a process for periodic review and update of publicly available documents – particularly those related to regulatory requirements – to not only ensure accuracy but also to demonstrate that they do, indeed, have such a process!). But nothing has changed, so should I assume that this product line is essentially illegal in most markets around the world? And if so, why are they still selling it?
Three proposed POPs are currently used in electronic components:
- Dechlorane Plus is a relatively commonly used halogenated flame retardant
- UV-328 is a UV absorber used on LCD panels and elsewhere
- Medium-chain chlorinated paraffins (MCCPs) are a combination halogenated flame retardant and plasticizer used like SCCPs in PVC. Note that MCCPs have also been proposed for restriction by EU RoHS.
The meeting of the Persistent Organic Pollutants Review Committee (POPRC) held in September this year addressed these three substances as follows:
- Adopted the risk management evaluation for Dechlorane Plus and recommended listing Dechlorane Plus in Annex A with specific exemptions
- Adopted the risk management evaluation for UV-328 and recommended listing UV-328 in Annex A with specific exemptions
- Adopted the risk profile for chlorinated paraffins with carbon chain lengths in the range C14-17 and chlorination levels at or exceeding 45 per cent chlorine by weight, established an intersessional working group to prepare a draft risk management evaluation and invited parties and observers to submit Annex F information on socio-economic consideration
This means that Dechlorane Plus and UV-328 are now poised for elimination and MCCPs are moving toward elimination. Ultimately this is at least a couple years away due to the fact that they have to first be approved for addition to Annex A of the Stockholm Convention (this is slated to occur at the next meeting in May 2023) and then be transcribed into local regulations around the world. So now is the time to remove these substances from your supply chain if your products are not included in the proposed list of exempt applications (an “advance” report listing those proposed exemptions is now available for Dechlorane Plus and UV-328 at the link above).
SCIP Database Pollution
The ceramic in certain capacitors is manufactured with diboron trioxide (CASRN 1303-86-2), which is a REACH SVHC, and the glass materials in certain resistors are manufactured with lead monoxide (CASRN 1317-36-8) and other oxides of lead that are also REACH SVHCs. As I have noted before, in most cases these are merely ingredients and are not present as such in the finished product. They contribute their constituent atoms to the formation of ceramics and glass, respectively, and cease to exist in their original molecular form.
Despite this, component manufacturers continue to disclose these and other ingredients without sufficient explanation that they are not actually present in the product. The result is that these non-existent SVHC substances are being added to the ECHA SCIP database, which is incorrect and effectively pollutes it. I searched on “lead monoxide” and got 1,371,593 results, which represent 15 percent of the entries in the database. While not all of them are incorrect, given what I see in the database and from the supply chain, most of these entries should not be there.
I see two possible approaches to solving this issue:
- Manufacturers, along with JEITA and ZVEI, can educate customers that these are ingredients, not constituents of the components they are purchasing.
- Manufacturers can stop providing ingredient information and determine a common and meaningful approach to specifying the constituent atomic composition of ceramics and lead. Most customers are not concerned – for now – about ingredients and process substances (this is also an issue for multi-ingredient thermosets like epoxy mold compounds). Giving this information to them results in inaccuracies in their database and in downstream reporting.