“RoHS 3 is coming! RoHS 3 is coming! What can you tell us about the impending regulatory apocalypse, oh Guru?”

Well, if I were said guru, I’d recommend limiting the time you spend watching weekend alien invasion marathons on the Sci-Fi Channel. Next, I’d advise you to step back and take a few deep breaths, because this is not as major of a change as it appears on paper.

First, a little background: RoHS, or the Restriction of Hazardous Substances Directive, was first adopted into law by the European Union as Directive 2002/95/EC in 2003 (taking effect in 2006) and was designed to reduce and restrict the use of various hazardous substances in electronic equipment. Since then, it’s spilled over into other industries, such as thermoplastics.

RoHS was initially concerned with six substances – lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls, and polybrominated diphenyl ethers. Additionally, RoHS specified 11 categories of materials for which these restrictions applied. Europe isn’t the only government to restrict these specific substances. In the U.S., the Coalition of Northeastern Governors’ legislation included regulations on lead, mercury, cadmium, and hexavalent chromium.

In 2011, “RoHS 2” came into being as 2011/65/EU and superseded 2002/95/EC. However, the list of chemicals addressed did not change. In fact, the only portion of the legislation that changed was the scope of products that it covered. Still, the amended bill required new documentation stating that 2011/65/EU covered any resins purchased.

That brings us to the current 2015/863, or as it’s better known, “RoHS 3.” The most significant change to this iteration is the restriction of four additional phthalates – specifically, Bis(2-ethylhexyl) phthalate (DEHP), Benzyl butyl phthalate (BBP), Dibutyl phthalate (DBP), and Diisobutyl phthalate (DIBP). If you’re starting to panic again, keep in mind that there’s still time – this latest amendment pertains to products placed on the market on or after July 22, 2019.

So, what exactly do these impending restrictions mean for you?

Other than eventually updating paperwork, virtually nothing. There’s already legislation restricting the use of these chemicals, and they are already on the Candidate List of Substances of Very High Concern (SVHC). Most resin producers have not yet updated their RoHS statements to reflect 2015/863, but providing a current RoHS declaration regarding any phthalates used should prove satisfactory. Rest assured that M. Holland will add formal RoHS 3 documents to our regulatory library as we receive them from our suppliers, providing our customers with the most accurate information as it’s available.


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