Critical Links

The European Commission granted an exemption for Decabromodiphenyl ether (DecaBDE) in October 2005, mainly as a result of a comprehensive risk assessment that showed that this flame retardant did not pose a risk to human health or to the environment (although more research was required).

As a consequence, Denmark and the European Parliament challenged this decision at the European Court of Justice and on April 1, 2008, the court ruled that the Commission had not followed the correct procedure as laid down by Article 5.1b of ROHS, and so the exemption would be deleted. The Court allowed three months to allow time either for manufacturers to change their products or for the Commission to correct their mistake. Neither is long enough, and so the result will be that this exemption ends on June 30, 2008. Few manufacturers will be able to meet this deadline and so many products will not comply with ROHS.

This is very significant for the electronics industry. DecaBDE is a very common flame retardant and is used in a lot of components and equipment currently on the market:
-HIPS enclosures
-PE wire insulation
-PP mouldings
-PBT connectors
-Also in Nylon 6 and several other plastics.

Where suppliers have provided material declarations that state which ROHS exemptions are utilized, these would state if DecaBDE is present and so the manufacturer will know what to do. However most declarations do not include this information (sometimes only that exemptions are utilized, but not which ones). Equipment producers and distributors will now need to find out if DecaBDE is present.

The first thing to do is to try is ask suppliers, but unfortunately, in some cases they will not know. If no indication can be obtained from suppliers, then the only options are:
-Assume they are not ROHS compliant so can be used only in products that are out of scope of ROHS, or
-Chemical analysis. This is a two-step process:
XRF or EDX for presence of bromine. If present this indicates only that one of the many brominated flame retardants is present. If bromine is present, identify which flame retardant using GCMS.

The DecaBDE exemption ends July 1, 2008 so there is little time to resolve this. This will be a significant issue for component suppliers as some of their customers will no longer accept plastics with DecaBDE, due to the timescale from buying parts to putting finished products on the market. It will also be a significant problem for manufacturers who have stocks of parts containing DecaBDE that cannot be used in ROHS compliant equipment that is put onto the EU market from July 1, 2008.

Share your thoughts on the end of the DecaBDE exemption below.

About the author
As director of legislation and environmental affairs, Gary Nevison is Newark's and Farnell's spokesperson and customer interface on legislation that affects the electronics industry, such as the ROHS (all variations around the world, including China ROHS), REACH, EuP, and WEEE directives. For more on Gary, click here.