| The Norwegian Government is proposing restrictions on 18 substances some of which will go beyond those in place in the rest of the EU. Hence, this could cause difficulties for manufacturers.
Norway plans to amend its “Regulations relating to restrictions on the manufacture, import, export, sale and use of chemicals and other products hazardous to health and the environment (Product Regulations)” which is Norway’s national legislation that implements the EU Marketing and Use Directive plus RoHS, packaging and batteries.
The proposals are: |
|
to restrict specified substances in consumer products only |
|
to provide exemptions including for medical equipment and all types of transport |
Note that exemptions do not exclude restrictions on lead and cadmium in monitoring and control instruments (RoHS Category 9) or other materials used in all types of electrical equipment that are not specifically excluded by the Norwegian legislation.
| The substances proposed for restriction are: |
Substance |
Concentration
Limit (%) |
Uses |
Exemptions (electronics Related) |
| Hexabromocyclododecane (HBCD) |
0.1 |
Flame retardant in extruded and expanded polystyrene and flexible PU foam |
- |
Tetrabromobisphenol A (TBBPA) |
1.0 |
Reactive flame retardant in epoxy laminate and additive in ABS |
- |
Chlorinated paraffins |
0.1 |
Plasticisers in paints and plastics, in cutting fluids |
- |
Arsenic, metal and compounds |
0.01 |
Semiconductors, alloy additive |
Lead acid batteries, brass, crystal and lead glass |
Lead, metal and compounds |
0.01 |
Solders, coatings, PVC stabiliser, inks and paints, etc. |
Glazing and enamels, crystal and lead glass, lead acid batteries, Paints, packaging, batteries and EEE that are already covered by Norwegian legislation |
Cadmium, metal and compounds |
0.01 |
Pigments, stabilisers, contacts, sensors |
Electric contacts and coatings to ensure reliability, paints and lacquers with high zinc content - Cd permitted to 0.1%, cadmium pigments, stabilisers and coatings for safety reasons, where cadmium is already restricted by Norwegian legislation |
Tibutyl and triphenyl tin compounds |
0.001 |
Biocide |
Where these are already restricted by Norwegian legislation |
Musk xylene and musk ketone |
0.05 each |
Fragrance used in household cleaners, etc. |
Where these are already restricted by Norwegian legislation |
Perfloro-octyl acid salts and esters |
0.005 (1µg/m 2 in textiles and coatings) |
Semiconductor manufacture, hard chrome plating |
|
DTDMAC, DODMAC, DSDMAC and DHTDMAC |
0.1 (in total) |
Surfactants |
Where used as washing agents and already restricted by Norwegian legislation |
Bisphenol A |
0.005 then 0.0025 |
Intermediate used for polycarbonate and epoxy resins but may be present as impurity |
Certain applications not related to electronics |
Diethylhexyl phthalate (DEHP) |
0.1 |
Main use is plasticiser for PVC (cables, etc.) |
Outdoor construction materials and applications already restricted by Norwegian legislation (e.g. toys) |
Pentachlorophenol (PCP) |
0.1 |
Pesticide and wood preservative |
Where this is already restricted by Norwegian legislation |
Triclosan |
0.001 |
Antibacterial and antifungal agent |
Where this is already restricted by Norwegian legislation |
Implications
These proposals could have significant implications for manufacturers of electrical equipment that is not excluded from this proposed legislation, notably monitoring and control instruments that are intended for sale to consumers. These products are not included in the scope of RoHS and so are therefore not specifically excluded from this new proposal.
The new restrictions on materials that will have the greatest impact on electrical equipment that is in scope are likely to be lead, cadmium, HBCDD, TBBPA and DEHP all of which are widely used in consumer smoke detectors, carbon monoxide detectors, multimeters, cable detectors, home electronic thermometers and barometers, etc. Note also that the concentration limit for lead is lower (i.e. more stringent) than that required by the RoHS Directive and is more restrictive than the recently proposed Danish lead restrictions.
The ban on DEHP goes much further than the EU ban that only affects children’s toys and childcare products. This legislation bans DEHP in all applications except those specifically excluded (medical and transport). The situation with TBBPA and HBCDD which are not restricted elsewhere in Europe is similar.
The EU is carrying out risk assessments on many of the substances included in these proposals. Many of these are incomplete and the assessment of TBBPA has so far found no risk except that under certain conditions it can degrade to Bisphenol A.
Norway originally planned to impose these restrictions on 1 st January 2008 but their Government official responsible has told ERA that this will be delayed as they are considering 90 responses to their stakeholder consultation.
Further information
For on advice on how to respond to these developments contact us on +44 (0)1372 367444 or email. To keep up to date on development on substance restrictions worldwide subscribe to
RE 4view, ERA’s environmental newsletter from which this article was taken.
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Norway to restrict more substances
