Version 6.4

🚀 Released on 23rd July 2021

The following 30 minute video explains what types of materials and parts can contain these new REACH Candidate List substances and Proposition 65 substances and how to update your Regulatory Compliance Declarations (RCDs) for these substances.

Version Details

New REACH Candidate List Substances

On 8 July 2021 the European Chemicals Agency added eight new substances to the REACH Candidate List (http://echa.europa.eu/web/guest/candidate-list-table). Five of these substances are not normally found in concentrations > 0.1% w/w in supplied articles

• 1,4-dioxane
• Glutaral
• 2-(4-tert-butylbenzyl)propionaldehyde and its individual stereoisomers
• Phenol, alkylation products (mainly in para position) with C12-rich branched alkyl chains from oligomerisation, covering any individual isomers and/ or combinations thereof (PDDP)
• 2,2-bis(bromomethyl)propane-1,3-diol (BMP); 2,2-dimethylpropan-1-ol, tribromo derivative/3-bromo-2,2-bis(bromomethyl)-1-propanol (TBNPA); 2,3-dibromo-1-propanol (2,3-DBPA) BOMcheck has automatically updated your Regulatory Compliance Declarations for these five new substances.

The following three REACH Candidate List substances can be found in concentrations > 0.1% w/w in supplied articles:

Substance	Likely to be found in supplied articles?
Medium-chain chlorinated paraffins (MCCP) [UVCB substances consisting of more than or equal to 80% linear chloroalkanes with carbon chain lengths within the range from C14 to C17]	Yes - substance can be used as an antioxidant and stabiliser in the manufacture of rubber and plastic products. The typical addition rate in these applications is between 0.1-1% w/w.
4,4'-(1-methylpropylidene)bisphenol	Unlikely - Bisphenol B (BPB) can be used as an alternative to Bisphenol A (BPA). As such, BPB can be used in thermal paper applications up to 3% by weight of the paper, and as an antioxidant additive in PVC where it can be present up to 1.2% by weight of the PVC. BPB can also be used as an ingredient in the manufacture of polycarbonate plastic, epoxy resins and other polymers, however the residual level of BPB in the manufactured materials is below 0.01%.
Orthoboric acid, sodium salt	Unlikely - Orthoboric acid, sodium salt has similar properties to the other sodium borate substances and may be used as an alternative to these substances. Borates can be used in wooden veneer sheets and pressed wooden panels, as a constituent within the starch adhesive, as a flame retardant and also as stabilizer in aminoplastic resins. Borates can also be used as a biocide in professional and industrial wood preservation.

New Proposition 65 substances

On 19 March 2021 OEHHA added the following two substances to Proposition 65

• Indium tin oxide
• Molybdenum trioxide

Both of these substances can be found in supplied articles and may require notification:

• skin contact with Indium tin oxide is expected when this substance is used as a thin film in flat-panel displays and touchscreens.
• exposure to Molybdenum trioxide is possible when this substance is used as an additive flame retardant in PVC, other plastic polymers and in textiles (e.g. carpet backing). Annex III exemptions that have expired for use in Category 1 – 7 and 10 equipment

The following Annex III exemptions applicable to Category 1 – 7 and 10 did not receive a valid renewal request and so expired on 21 July 2021 for Category 1 – 7 and 10, however they are still valid for use in Category 8 and 9 equipment

• 21(a)
• 21(b)
• 21(c)

BOMcheck Version 6.4 displays the part as non-compliant to RoHS when the “Electrical and mechanical products” (default) filter is applied and the part claims any of these three Annex III exemptions. The part is displayed as being compliant to RoHS when the “Medical devices” filter is applied if the part claims any of these three Annex III exemptions.

Annex III exemptions that have expired for use in all types of equipment

The following 14 Annex III exemptions applicable to Category 8 and 9 did not receive a valid renewal request and so expired on 21 July 2021 for Category 8 and 9

• 5(a)
• 7(b)
• 7(c)-IV
• 9
• 9(b)
• 17
• 21
• 25
• 30
• 31
• 33
• 37
• 38
• 41

BOMcheck Version 6.4 displays the part as non-compliant to RoHS when the “Electrical and mechanical products” filter is applied or the “Medical devices” filter is applied, and the part claims one of these 14 Annex III exemptions. In other words, these 14 Annex III exemptions are treated as if the supplier had answered Compliance = No to the RoHS substance.

Annex IV exemptions that have expired for use in all types of equipment

The following 15 Annex IV exemptions applicable to Category 8 and 9 did not receive a valid renewal request and so expired on 21 July 2021 for Category 8 and 9

• 4
• 6
• 7
• 8
• 1d
• 9
• 10
• 16
• 18
• 19
• 20
• 22
• 23
• 25
• 34

BOMcheck Version 6.4 displays the part as non-compliant to RoHS when the “Electrical and mechanical products” filter is applied or the “Medical devices” filter is applied, and the part claims one of these 15 Annex IV exemptions. In other words, these 15 Annex IV exemptions are treated as if the supplier had answered Compliance = No to the RoHS substance.

Updating Declarations

IF YOU HAVE CREATED FULL MATERIALS DECLARATIONS (FMDs) ON BOMcheck THEN YOU WILL NOT NEED TO TAKE ANY ACTION. The RCDs which are generated from your FMDs have been updated automatically for these eight new REACH Candidate List substances and two new Proposition 65 substances. The Approval Date for RCDs has been set to 23 July 2021. The Approval Date for your FMDs remains the same.