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December 10, 2019

Welcome to the December 2019 Design Chain Associates E-mail Newsletter! Happy Holidays from DCA!

In addition to DCA's newsletters, keep an eye on DCA's bi-monthly column in TTI's MarketEYE Resource Center.

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RoHS Stakeholder Consultation - 3 Substances and Prioritization

Last week the Öko-Institut opened up a new stakeholder consultation on the three remaining substances proposed for restriction under the RoHS Directive:

Öko-Institut's bottom line and rationale for these three substances is interesting but not unexpected

ATO: if ATO on its own is restricted, there is a risk of regrettable substitution since - as a consequence of this restriction - an increased amount of halogenated flame retardants is expected to be used, bringing along their predominant negative impacts on health and the environment. In order to avoid this, the consultant proposes not to exclusively restrict ATO, but instead to carry out an assessment of the system of halogenated flame retardants and the ATO synergist with high priority.

MCCPs: Öko-Institut recommends restricting a range of MCCPs, describing that this entry covers chlorinated paraffins containing paraffins with a chain length of C14-17 - linear or branched.

TBBPA: it is recommended to include this substance in the list of restricted substances with a limit value of 0.1 % per weight due to the described risks of TBBP-A and the availability of alternatives. Assuming good and controlled manufacturing conditions, reactive applications and in particular its use as a component of FR4 PWB would not be affected by this restriction, because the residual levels of TBBP-A would be below the proposed limit in this case.

Note that, In light of the upcoming ban of organohalogen flame retardants (OHFRs) in displays/monitors/TVs under the Eco-design Directive, as well as the relatively non-impactful restriction of TBBPA, this should be interesting. In my opinion, in order to effectively restrict ATO, they have to restrict the entire sub-class of OHFRs that ATO would be used with in polymers including PVC and others.

Not to be too overshadowed, another stakeholder consultation is concurrently open on "substance prioritisation" for 43 substances that could represent upcoming restriction proposals under RoHS. Öko-Institut is asking for quantitative usage data on these 43 substances.

Both stakeholder consultations are open until January 30, 2020.

ACS GCI Tools for Chemists

The American Chemical Society Green Chemistry Institute's (ACS GCI) Pharmaceutical Roundtable has been producing online tools to make processes greener for over a decade. Many of these tools are online, are not limited to processes in the pharma industry, and are publicly available; most are general-purpose and could be adopted by any manufacturer using chemistry in the manufacture of their products. These include

Forward this information on to your favorite chemists!

DCA Articles & DCA In The News

Catch-up on past DCA newsletters on our DCA In The News web page!

December 17, 2019 TTI MarketEYE: End-of-Year International Roundup. This may be the end of 2019 but the march of regulations impacting products shows no sign of waning. We cover an update on Brazil RoHS, Phase 2 of China RoHS, the European Commission's Green Deal, and a risk of widespread "regrettable substitution".

October 14, 2019 TTI MarketEYE: Ecodesign, RoHS and More: The EU Goes on a Tear. With short timelines and extensive requirements, the new ecodesign implementing measures challenge EEE manufacturers. I review the four RoHS proposals for restriction that have been opened up as well.

September 25, 2019 DCA Newsletter: September 2019. An awful lot going on in the European Union.

Events to Attend

March 23-24, 2020: Chemicals Management for Electronics Europe 2020, Amsterdam, Netherlands. Mike discusses what European manufacturers must understand about California Proposition 65.

June 16-18, 2020: 24th Annual Green Chemistry & Engineering Conference, Seattle, Washington. DCA, US EPA and Planet Singular will hold a session on semiconductors and electronics. The call for presentations opens in early January so if you're interested in presenting please get in touch!

More to come! Stay tuned.

Contact and Feedback

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This newsletter covers only a fraction of how we support our clients. DCA offers expertise and consulting services in all the areas covered above, as well as many others. Please contact us to discuss your needs.

Best Regards,
Michael Kirschner

Design Chain Associates LLC

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