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Home > Nanotechnology Columns > Bergeson & Campbell, P.C. > Recast RoHS Directive: Nano Implications

Lynn L. Bergeson
Managing Director
Bergeson & Campbell, P.C.

Abstract:
The recast of the Directive on the Restrictions of Hazardous Substances (RoHS) was published in the July 1, 2011, Official Journal of the European Union. The notice calls for the restriction of other hazardous substances and their substitution by more "environmentally friendly alternatives." Importantly for nano stakeholders, the notice specifically states that these "other hazardous substances" include "any substances of very small size or with a very small internal or surface structure (nanomaterials) which may be hazardous due to properties relating to their size or structure."

July 8th, 2011

Recast RoHS Directive: Nano Implications

The recast of the Directive on the Restrictions of Hazardous Substances (RoHS) was published in the July 1, 2011, Official Journal of the European Union. The notice calls for the restriction of other hazardous substances and their substitution by more "environmentally friendly alternatives." Importantly for nano stakeholders, the notice specifically states that these "other hazardous substances" include "any substances of very small size or with a very small internal or surface structure (nanomaterials) which may be hazardous due to properties relating to their size or structure."

As reported previously, proposed restrictions on additional substances, including nanosilver and long multi-walled carbon nanotubes, were not supported by the European Union (EU) Council and were not included in the version of the legislation passed by both the EU Council and European Parliament (EP). The Final Report on the Recast RoHS Directive prepared by the Committee on the Environment, Public Health, and Food Safety Committee (ENV Committee) in June 2010 proposed that nanosilver and long multi-walled carbon nanotubes be added to Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) Annex IV, which contains a list of materials prohibited for use in electrical and electronic waste.

When the EP considered the Recast of the Directive during its plenary meeting on November 22-25, 2010, the agreed upon text only contained a reference to nanomaterials in one of the recitals to the RoHS Recast, as follows:

As soon as scientific information is available, and taking into account the precautionary principle, the restriction of other hazardous substances, including any substances of very small size or internal or surface structure (nanomaterials) which may be hazardous due to properties relating to their size or structure, and their substitution by more environmentally friendly alternatives which ensure at least the same level of protection of consumers should be examined.

This, of course, is the language that was formally adopted and appears in the Official Journal. See http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:174:0088:0110:EN:PDF

While the RoHS Recast does not impose any obligations for companies placing electrical and electronic waste containing nanomaterials in the EU market, the language noted above and the consideration of the EP are instructive and suggest future regulation of nanomaterials in the EU may be in the offing. REACH, as opposed to RoHS, is the more likely venue where a more comprehensive review of nanoscale materials is likely. As readers may know, a specific working group was created under REACH for this purpose, and preliminary conclusions are expected to be released soon. These conclusions will influence the commercial profile of nanomaterials in electrical and electronic waste and beyond for years to come.

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