Dear members,
Please see below update we have received from MedTech Europe regarding the proposed inclusion of TBBP-A and MCCP in the scope of EU RoHS.
I hope you are all well.
We would like to share an update with you regarding the status of the inclusion of TBBP-A and MCCP in RoHS.
A few years ago, as part of the so-called “Pack 15”, the Commission had tasked the consultant Oeko to prepare an assessment into whether more substances should be added to RoHS Annex II, which contains the list of the restricted substances in the scope of RoHS. Oeko published a study assessing 7 potential substances, of which, two were recommended for inclusion, namely TBBP-A and MCCP.
Since this report was published, a decision was pending to see if the Commission would follow that recommendation. Over the years, we had understood informally that they would not be pursued under RoHS, as MCCP was already being considered for a REACH Restriction and TBBP-A would fall under the ECHA investigation on a potential Restriction of Aromatic Brominated Flame Retardants (ABFR), as part of the EU Flame Retardant Regulatory Strategy.
This topic has now officially been closed, as the Commission published on 10 December information that the inclusion of MCCP and TBBP-A has been abandoned (link).
As MedTech Europe, the two substances remain relevant as, MCCP is proposed for inclusion in the Stockholm Convention on POPs, whereas TBBP-A is under consideration for a potential REACH Restriction on ABFR. MedTech Europe has already engaged this year in the ECHA ABFR consultation and we have launched a request for impact on members from a potential Stockholm Convention listing of MCCP until 10 January.
Please let us know if you have any questions or comments.
