Se ha publicado en la página web de CIRCABC el Expediente para el DIBP (Diisobutylphthalate) del Anexo II de la RoHS.de DIBP.
Este Expediente ha sido preparado por la consultora Öko-Institute sobre la base de la plantilla publicada por la Austrian Umweltbundesamt GmbH, como parte de los documentos de referencia de la tercera consulta realizada durante el proyecto.
El Öko- Institute concluye que :
“there appears not to be a justification for currently restricting DIBP on its own. If DEHP, DBP and BBP are not to be restricted through RoHS, the consultants do not see a need for the restriction of DIBP in light of its limited applicability to EEE and the low probability for this to change.
There are, however, two options for action, should it be decided to restrict the other phthalates under the RoHS Directive. In both cases, it should be noted that since DIBP is on the REACH Regulation Authorisation List (Annex XIV), its trend of manufacture and use is not expected to change within the EU, whereas for imported goods and components there is a requirement to report its content in such articles to any recipient of the article (manufactures using components containing the substance or importers acquiring products containing the substance for the EU market).
The stricter possibility would be to tie the restriction of DIBP with the restriction of DEHP, DBP and BBP. In this case, if DEHP, DBP and BBP are to be restricted through the RoHS Directive, DIBP would be restricted subsequently. As the main motive for this restriction is to prevent possible substitution of one phthalate with another, it should further be considered if this would not justify grouping the phthalates for the purpose of restriction. The four phthalates DEHP, BBP, DBP and DIBP could be grouped as “classified phthalates” (phthalates on the REACH Authorisation list for the reason of reproductive toxicants category 1B). The grouping of similar substances is mentioned in Article 6 (1) of RoHS 281. The similarity is due to the same classification under REACH and the inclusion on the Authorisation list. Additionally, the four phthalates are Low Molecular Weight (LMW) phthalates (low phthalates include those with 3-6 carbon atoms in their chemical backbone)82. In this case the RoHS compliance monitoring of EEE could run the four phthalates in parallel.
The second possibility, which is expected to be more favourable for industry (though with a greater risk for increase of DIBP use in EEE), would be to postpone the decision on the restriction of DIBP, revisiting its necessity based on changes in the trend of use in EEE. In other words, at present DIBP would not be included in Annex II of RoHS and would thus not be restricted for use in EEE through the RoHS Directive. In this case market surveillance of DIBP in EEE would need to be carried out in parallel to the other phthalates83 in order to monitor changes in the trend of use. Should an increase in use be observed, the restriction would be reconsidered. It would be recommended in this case to revisit the possibility of a restriction from time to time to create an incentive for industry not to phase in DIBP, for instance every 5-7 years. It would further be beneficial in this course of action to reach an agreement with the EEE industry towards a voluntary non-use of DIBP.”