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    The Indian Government has published its proposals for legislation on the disposal of waste electrical and electronic equipment. This includes what is referred to as reduction in the use of hazardous substances. This refers to schedule III which lists 20 individual substances and threshold limits but the intention of this requirement is not clear. For example, the proposals:

    • do not say whether these substances are restricted or that manufacturers should attempt to avoid them,
    • do not state whether the threshold values refer to the concentrations in the finished product, in homogeneous materials or something else,
    • provide no exemptions or any mechanism for requesting exemptions,
    • lack clarity about limits. Several of the substances have a range of threshold values in Schedule III. For example, it includes cadmium oxide as  “>=0.1% to 25% depending on risk phrase or perception”

    The scope of the proposed legislation is similar to the EU WEEE directive and includes medical devices and monitoring and control instruments. However, EU-RoHS substance restrictions do not apply to medical devices or monitoring and control instruments at present.

    The substances in Schedule III are:


    Threshold limit


    Short chain chloro paraffins (SCCP)


    Plasticiser and fire retardant, In cutting oils

    Antimony trioxide


    Flame retardant and used to make some types of glass (little evidence of risk)

    Beryllium metal


    X-ray transparent windows

    Beryllium oxide


    Dielectric that is the best thermal conductor, also the most expensive so used only if there are no alternatives



    Plating and in some alloys

    Cadmium oxide

    >=0.1% to 25%

    Electric contacts

    Cadmium sulphide

    >=0.1% to 25%

    Photocells, some types of audio opto-coupler and in some types of photovoltaic modules

    Chromium VI

    >0.1% to 0.25%

    Passivation coatings and used to make hard chromium plating

    Copper beryllium alloys

    >0.1% to 3%

    Springs, for example used in connectors.  This is the most expensive spring alloy so is used only if there are no alternatives

    Decabromodiphenyl ether


    Flame retardant (restricted by EU-RoHS)



    Solders, radiation shielding, counterweights

    Lead oxide

    >0.5% to >=25%

    Uncommon in electronics

    Liquid crystals


    Liquid crystal displays


    >=3% to >=0.25%

    Tilt switches, sensors, thermometers, mercury wetted reed relays, thermostats.  Largely replaced in the USA and EU.

    Mineral wool

    >=1% to >=20%

    Heat shields, thermal insulation

    Octabromodiphenyl ether


    Flame retardant banned in the EU

    Polychlorinated biphenyls


    Should no longer be used due to worldwide ban



    Wire insulation, mouldings (not a hazardous substance but emits toxic dioxins and furans if burned in open fires)

    Refractory ceramic fibres

    >=1% to >=20%

    Heat shields, thermal insulation



    Flame retardant in HIPS, reactive FR in PCB laminate, EU risk assessment concluded that this poses no risk

    It is understood that this legislation is being promoted by “Green Groups” such as Greenpeace and a few manufacturers who have “green policies” that already restrict most of the substances in Schedule III. The list of substances contains some surprises. For example it includes deca-BDE and octa-BDE but not penta-BDE. It includes TBBPA, which is not thought to pose a risk, while HBCDD is not listed even though is an EU REACH SVHC. It lists substances which have no alternatives and so reduction in use would not be possible. One of the aims of this legislation is to require all Indian recyclers to register and be authorised. This is intended to eliminate the dangerous backyard recycling that is still carried out in India and to ensure that all Indian WEEE is recycled safely. This would eliminate the need to restrict organohalogens such as PVC and TBBPA as these substances can be recycled safely by modern recycling processes.

    The proposals would require manufacturers and importers to supply only “RoHS-compliant” products (whatever this means) and to provide written documentation with regard to compliance and to include details on these substances in the product information booklet. These requirements would enter force three years after adoption of this legislation.

    With thanks to Cobham Technical Services


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