The EU RoHS substance review is in full swing. The Oko Institut, who is conducting the review, has drawn up a list of 46 substances for scrutiny. According to the covering letter the list "is based on declarations provided by suppliers and manufacturers of EEE, existing studies, XRF-analyses and other information." This list and covering letter are available at http://hse-rohs.oeko.info/index.php?id=3

The Oko Institut are calling for industry input, however time is limited as responses need to be sent to hse-rohs@oeko.info by 28 March 2008. A  quick turn around is anticipated as their letter states "For each of the potential candidate substances policy options will be recommended in the draft final report that will be published by mid of April." This gives only 2 weeks for assessing the results of the consultation.

Interestingly, the criteria of selecting these substances are evocative of REACH not RoHS. The criteria were "substances classified as CMR, PBT / vPvB or endocrine disruptors" and were drawn from Directive 67/548/EEC - which has been superseded by (incorporated into) REACH. The criteria and the term 'candidate list" are used in REACH for forming the list of Substances of Very High Concern. It is substances on this list in REACH that will be assessed for restrictions.

The IPC have called for any additional substance restrictions to come under REACH.

Similarly the joint submission from AeA and EICTA  stated "During the legislative process on the REACH (Registration, Evaluation and Authorization of Chemicals - 2006/121/EC) Regulation a key rationale for the Regulation and inclusion of articles and notification requirements was to obviate the need for sector-specific legislation."

All of these indicators are pointing to a logical conclusion. Bringing future restrictions under REACH makes sense. All of the 6 RoHS substances are used in many other industry sectors and there is nothing particularly special about the materials used in Electrical and Electronic Equipment. Nonetheless it is prudent for any company who is affected by RoHS to educated themselves on the substance restriction requirements of REACH.

To help with this RoHS-International have recently revised their "Simplified Guidance Notes for Article Producers" to detail the restriction process under REACH, and how the restrictions may be applied. These are available from http://www.rohs-international.com/reach/ for a small charge.