applications, aerospace, chemical processing, building construction, automotive, electronics, energy, environmental protection, and outdoor and technical apparel. Substance restrictions around the world have not identified the use of all fluoropolymers (e.g., PTFE, FEP, PFA) as an area of concern. Halogens are not as a group generally hazardous to the environment, so the inclusion of all halogens in the definition would create unnecessary problems for the electronics industry. Creating a scientifically accurate standard but not dealing with environmental aspects relevant to EEE products is not in the scope of TC 111. NL 12 090-92 4 te It does not make sense to also include Criteria 3 Change second part of the definition to (for information only) substances in the definition meet the thresholds of all hazardous “…and of halogen since the objective of “Low materials”, halogenated Criteria 1+2 substances in the IEC this definition is to include regulated substances 62474 database” that have already been accessed and were demonstrated to pose issues to health and environment when used in EEE Please also note the voting round held during the PT63031 meeting in Wilmington on May 18, 2017 NL 13 090-92 4 te Any limit referred to in this definition shall be Change the definition to: based entirely on scientific evidence of an defined as Halogenated Materials “Materials “Low adverse environmental impact in the case such of Concern” shall contain less than 0,9% (by limit is exceeded. The limit of 0,9% lacks mass) total elemental halogen content (F+Cl+Br+I) scientific evidence of adverse environmental and meet the thresholds of all hazardous impact, and therefore must not be used in a halogenated Criteria 1+2 substances in the IEC standard -- or otherwise we will be making 62474 database” legislation instead of a standard. AND add the following sentence : The link with IEC 62474 Criteria 1+2 can be The above definition excludes non-hazardous accepted as the substances in these categories halogenated substances included in the IEC are already accessed for their harmful behaviour 62474 database for reporting purposes to environment (or health) Note that IEC 62474 Criteria 3 substances are not determined as concern materials and shall therefore be excluded from the definition CN-1 090-93 4 technical There is no scientific basis to to restrict all Delete less than 0,9% (by mass) total “contain
applications, aerospace, chemical processing, building construction, automotive, electronics, energy, environmental protection, and outdoor and technical apparel. Substance restrictions around the world have not identified the use of all fluoropolymers (e.g., PTFE, FEP, PFA) as an area of concern. Halogens are not as a group generally hazardous to the environment, so the inclusion of all halogens in the definition would create unnecessary problems for the electronics industry. Creating a scientifically accurate standard but not dealing with environmental aspects relevant to EEE products is not in the scope of TC 111. NL 12 090-92 4 te It does not make sense to also include Criteria 3 (for information only) substances in the definition of “Low halogen materials”, since the objective of this definition is to include regulated substances that have already been accessed and were demonstrated to pose issues to health and environment when used in EEE Please also note the voting round held during the PT63031 meeting in Wilmington on May 18, 2017 Change second part of the definition to “…and meet the thresholds of all hazardous halogenated Criteria 1+2 substances in the IEC 62474 database” NL 13 090-92 4 te Any limit referred to in this definition shall be based entirely on scientific evidence of an adverse environmental impact in the case such limit is exceeded. The limit of 0,9% lacks scientific evidence of adverse environmental impact, and therefore must not be used in a standard -- or otherwise we will be making legislation instead of a standard. The link with IEC 62474 Criteria 1+2 can be accepted as the substances in these categories are already accessed for their harmful behaviour to environment (or health) Note that IEC 62474 Criteria 3 substances are not determined as concern materials and shall therefore be excluded from the definition Change the definition to: “Materials defined as “Low Halogenated Materials of Concern” shall contain less than 0,9% (by mass) total elemental halogen content (F+Cl+Br+I) and meet the thresholds of all hazardous halogenated Criteria 1+2 substances in the IEC 62474 database” AND add the following sentence : The above definition excludes non-hazardous halogenated substances included in the IEC 62474 database for reporting purposes CN-1 090-93 4 technical There is no scientific basis to to restrict all Delete “contain less than 0,9% (by mass) total
PT63031_0080_CC.docx