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SHARED CHEMICALS BETWEEN ROHS, REACH, POP, PROP. 65, AND TSCA

As you know, various chemicals are hazardous to the environment or humans globally. To no one’s surprise, different jurisdictions have decided to regulate these same chemicals in manufactured articles.

However, the way they control them may differ from one jurisdiction to another.

Product Environmental Compliance: Examples of Substances under Different Regulations

Markets like the European Union (EU), the USA, or Canada constantly assess, monitor, and regulate new chemicals as science progresses and identifies hazards.

Here are examples of some of the main chemicals under at least two distinct regulations:

Chart showing substances in common between RoHS, REACH, POP and Prop. 65
Substance Name CAS# Where used (examples) Where Regulated (examples)
Alkanes, C10-13, chloro (Short Chain Chlorinated Paraffins, SCCPs) 85535-84-8 Flame retardant Additive in metal working, in rubber, and plastics (e.g., cables) EU POP (Persistent Organic Pollutant) EU REACH SVHC
Bisphenol A (BPA)  80-05-7 Polycarbonate plastic, PVC Epoxy resins Thermal paper California Proposition 65 EU REACH SVHC
Cadmium   Lead 7440-43-9 7439-92-1 Electrical and electronic equipment California Proposition 65 China, EU, Korean, Russia, Taiwan, Turkey, UK, Ukraine, United Arab Emirates RoHS EU REACH SVHC and Annex XVII
DecaBDE – Decabromodiphenyl Ether   1163-19-5 Flame retardant China, EU, Korean, Russia, Taiwan, Turkey, UK, Ukraine, United Arab Emirates RoHS EU POP EU REACH SVHC US TSCA-PBT
Diisobutyl phthalate (DIBP) 84-69-5 Plasticizer EU RoHS EU REACH SVHC and Annex XVII
Hexachlorobutadiene (HCBD) 87-68-3 Solvent California Proposition 65 EU POP
Hexabromobiphenyl (HBB)   36355-01-8 Flame retardant China, EU, Korean, Russia, Taiwan, Turkey, UK, Ukraine, United Arab Emirates RoHS  
Pentabromodiphenyl ethers (PentaBDE) and its mixture   32534-81-9 and others  Flame retardant California Proposition 65 China, EU, Korean, Russia, Taiwan, Turkey, UK, Ukraine, United Arab Emirates RoHS EU POP
 Tetrabromodiphenyl ethers 40088-47-9 and others  Flame retardant China, EU, Korean, Russia, Taiwan, Turkey, UK, Ukraine, United Arab Emirates RoHS EU POP

The more a substance is widespread, known, or suspected to cause hazardous concern, the more it has chances to be controlled globally. It is the case of lead compounds. Nevertheless, one single market can also decide to regulate a specific chemical that no other jurisdiction would restrict elsewhere.

Same Substances but Different Product Environmental Obligations

Despite shared goals to restrict these substances, countries can decide to regulate them differently.

Varying Regulatory Scopes

Some regulations have a broad scope, such as US TSCA-PBTEU REACH, or California Prop. 65, which covers most manufactured products.

Others have a narrower scope and only target specific products. RoHS, dedicated to electrical and electronic equipment, is one of them. Even the RoHS scopes vary from a market to another. As a result, some RoHS regulations target consumer products only, while others also encompass professional devices.

The EU regulation 2019/2021 is another example. It only considers electronic displays and includes the restriction of chemicals like cadmium or halogenated compounds.

Chemical concentration in products

Distinct Chemical Concentration Thresholds in Products

Thresholds do not necessarily mean the limitation of substances in products.

For example, RoHS imposes restrictions on certain chemicals while REACH SVCH or Prop. 65 triggers the declaration of substances via a safe-harbor warning. For commercial reasons, a company may voluntarily reduce the number of declarable substances in its product recipes.

Environmental Compliance Marking

Environmental labels apply to some product requirements, but not to all. 

RoHS is part of the European CE marking obligations, while EU REACH does not require product marking. Instead, producers must notify the presence of Substances of Very High Concern (SVHC) via the SCIP database.

Need to demystify regulations of chemicals in your products? Ask Enviropass for a free consulting session!