Keeping Busy with Hazardous Substances, Environmental Regulations and E-Waste

Good Riddance SCIP?

The European Commission (EC) committed to reducing and simplifying administrative burdens in environmental regulations. As their first step, they’re gathering comments in a stakeholder consultation that is open from July 22 through September 10.

The associated Call for Evidence states that “The Commission is currently screening environmental laws to identify legislative acts with significant potential for simplifying administrative tasks. The aim is to reduce the administrative burden without affecting the environmental objectives agreed under the existing legislation.”

Everyone in the electronics industry can agree – I hope – that the Europeans have a leadership position in regulating the environmental performance of products as well as in the overall and aggregated complexity of these regulations. This complexity has resulted in some extraordinary inefficiencies that manufacturers and their supply chains have had to deal with.

Stated examples of measures that the EC may take include:

• Discontinuation of the SCIP database,
• Harmonization of the provisions for authorized representatives for EPR in each member state and
• Streamlining reporting obligations.

While fixing a lot of the problems with EPR (i.e., WEEE) throughout the EU should be high on everyone’s list, most interesting to me is the potential for elimination of the SCIP database. I’ve never believed that this database has much merit to begin with. What little it might have is certainly not commensurate with the extraordinary efforts and expenses that manufacturers and their supply chains have had to expend in order to produce data that, if not necessarily accurate, is acceptable to the extraordinarily rigid structural and data-intensive system.

The sad thing is that the defined purpose of the SCIP database – which is to enable recyclers to identify parts and materials that would need to be removed from products they receive in order to be separately treated – is a mere pipe dream. No recycler is going to spend time researching each item received in the SCIP database then disassembling it down to the specific bits and pieces that may contain SVHCs! They have neither the time nor resources to do that, but they do have a giant shredder that everything gets tossed into. I thought that a less unlikely purpose of the data may be to help the EC understand where certain SVHCs are used, but not only is the user interface too clumsy for that; they already have resources in the JRC or elsewhere, as well as the ability to require information to be provided from industry (i.e., a “data call”), to answer those questions.

So work with your peers, your suppliers, and your industry associations to develop some metrics about how much time, money, and human resources obtaining the data then generating and submitting the .i6z files to the SCIP database has taken for your company, if it can even be quantified. Make sure the EC gets the message about the lopsided cost to manufacturers of providing the information into the SCIP database with the insufficient evidence that the data is useful or usable by anyone for any particular environmental reason.

Medium-Chain Chlorinated Paraffins – the latest POP

As previously noted, the Stockholm Convention has been working on whether to list medium-chain chlorinated paraffins (MCCPs) as a persistent organic pollutant (POP). Recall that MCCPs were being considered for addition to EU RoHS as another restricted substance but that was formally abandoned last December.

At its most recent meeting, the Conference of the Parties to the Stockholm Convention on Persistent Organic Pollutants decided to amend Part I of Annex A (Elimination) to include MCCPs with specific exemptions, as documented in Decision SC-12/10, the Stockholm Convention . Note that these exemptions include wires and cables in the construction sector and medical device/in-vitro diagnostic devices as well as some other purposes until 2036.

The next step is for all the Parties to the Stockholm Convention to transpose this decision into their local regulatory structure. So expect to see every market, except the US – which never ratified the Convention – and Israel – which may now be moving toward ratifying the Convention, implement this ban over the next few years.

Quick Takes

Australia: Decabromodiphenyl ethane (DBDPE), the common drop-in replacement for decabromodiphenyl ether (DecaBDE), has now been banned per Compilation No. 4 of the Industrial Chemicals Environmental Management (Register) Instrument 2022. Schedule 6 indicates it comes into effect on January 1, 2027. There are some exemptions, including for electrical and electronic equipment until July 1, 2037, as it is (curiously) viewed as an “essential use.” DecaBDE is also restricted in this same section to 1000ppm in some applications but allowed at levels up to 10% by weight until January 1, 2027.

Brazil: Brazil RoHS has been dormant for several years. But it’s suddenly back in play. A new draft is in the review and comment process. Check it out here on the CONAMA web page.

European Union: Could the recast of the WEEE Directive finally be at hand? In addition to the simplification Call for Evidence mentioned above, the Circular Economy Act Call for Evidence says that the goal, as one might guess, is to increase circularity. One of the key aspects of the Act will be to address e-waste, “the fastest growing waste stream at 2% per year, of which less than 40% is recycled, to ensure its effective collection and recycling and to generate market demand for the secondary critical raw materials they contain. Existing rules may need to be revised to make them fit-for-purpose and simpler.” The existing rules vary from member state to member state, making registration and reporting an administrative headache. The WEEE Directive itself does nothing to drive reusability or recyclability, so there are clear gaps and issues that a recast could address. The comment period is open through November 6.

Minnesota: The PFAS reporting due date has been extended from January 1, 2026 to July 1, 2026. Don’t forget to budget for submission of your initial report.

Saudi Arabia: Numerous technical product regulations are being updated and notified to the WTO TBT Committee to align with an updated product safety law. The RoHS-like regulation is among them. You can download it here.

U.S.: EPA has again delayed the one-time TSCA Section 8(a)(7) PFAS reporting period to begin on April 13, 2026 and continue for six months to October 13, 2026 (small manufacturers only reporting as PFAS article importers have until April 13, 2027).

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