As you know, various chemicals are hazardous to the environment or humans globally. To no one’s surprise, different jurisdictions, like RoHS, REACH, Prop 65, have decided to regulate these same restricted chemicals in products. Let’s see the restricted substances list.
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:
| 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.
Despite shared goals to restrict these substances, countries can decide to regulate them differently.
Some regulations have a broad scope, such as US TSCA-PBT, EU 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.
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 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 restricted chemicals in products? Ask Enviropass for a free consulting session!
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