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Stakeholder consultation on medium chained chlorinated paraffins in electrical and electronic equipment

The Swedish Chemicals Agency is considering a proposal to restrict medium-chained chlorinated paraffins (MCCP) in electronics. MCCP is classified as environmentally hazardous and as toxic to reproduction. It is now possible to comment on the study in the open consultation.

Background

The Swedish Chemicals Agency is performing a study to assess the potential for substitution of Medium-chained Chlorinated Paraffins (MCCP) for uses in electric and electronic equipment. The use of chemical substances in electric and electronic equipment (EEE) is regulated under RoHS, the Directive 2011/65/EU. MCCP has earlier been brought up by the European commission as a candidate for prioritisation for restriction under RoHS.

As part of the study to investigate the need for and the possibility of a restriction, a consultant has been commissioned to write a report. The report includes:

  • scientific data on MCCP
  • legislative issues
  • information on the use of MCCP and harmful effects on human health and the environment
  • exposure in the waste management process
  • alternatives to MCCP
  • socio-economic assessment. 

Read the report on MCCP.

Medium-chained chlorinated paraffins...

...are alkanes, C14-17, chloro (CAS No: 85535-85-9, EC No: 287-477-0), otherwise known as MCCP. It is a group of organic substances with a carbon chain length between 14 and 17 containing varying amounts of chlorine, typically ranging from 40-63% w/w chlorine content.  MCCP is extensively utilised in flexible PVC as a secondary plasticiser and flame retardant. It is commonly used for EEE cable sheathing and insulation. An estimated 9,200 tonnes/year of MCCP is used for cable products. 

Participate in the consultation 

To make a contribution to the consultation, please review the report on MCCP and consider the questions below. You can provide your submissions following this questionnaire and include as much comprehensive information as possible. Other information or comments to the report are also appreciated.

Questions

Import and export
1. What is the amount of imported MCCP or MCCP-containing products per year to the EU?
2. What is the amount of exported MCCP or MCCP-containing products per year from the EU?

If available, data for specific geographical areas or subsets of products are also welcome.

Alternatives to MCCP
3. Are there any other substitutes available to MCCP than those mentioned in the report?
4. What would be the cost difference in using alternatives (primary plasticers, special plasticisers, and extender) for different actors?
5. What would the costs consist of (e.g. raw material, reformulation, new processes)
6. What would the benefits consist of (e.g. qualitative or quantitative information due to a decrease in the environmental impact ...)
7. What would be the economic impact on MCCP/ PVC/ cable/EEE manufacturers in case of a restriction compared to today?

Releases of and exposure to MCCP
8. What are the releases of and exposure to MCCP throughout its life cycle (including environmental monitoring), paying special attention to emissions during service life and the waste stage?

All data does not necessarily need to be exhaustive. Data for specific process stages, etc are welcome.

Submission and contact details

In case parts of your contribution are confidential, please clearly mark relevant text excerpts or provide your contribution in two versions (public and confidential).

Please do not forget to provide your contact details (Name, Organisation, e-mail and phone number) so that the we can contact you in case there are questions concerning your contribution.

Please email your contribution before 15 September 2017 to Johanna Löfbom at The Swedish Chemicals Agency; Johanna.lofbom@kemi.se

More information

Article 6(1) in the RoHS Directive (2011/65/EU) sets the rules for amending the list of restricted substances. For that purpose a template for a RoHS Annex II restriction dossier has been created. The report follows that template. Please, note that the assignment of the consultant did not comprise to conclude whether MCCP should be restricted under RoHS or not. 

In case we decide to go forward with a RoHS Annex II dossier for the restriction of use of MCCP in electrical and electronic equipment, the plan is to include relevant information from this stakeholder consultation and any other new information relevant to such a dossier (e.g. the recent decision on the listing of short-chained chlorinated paraffins (SCCP) in the Stockholm Convention).