In February 2020, i2a provided a comprehensive set of comments on the most recent assessment of the use of antimony trioxide (ATO) in electrical and electronic equipment (EEE). The assessment was performed under the EU’s Restriction of Hazardous Substances (RoHS) directive, by the Oeko
Institut and Fraunhofer for the EU Commission, in December 2019.
Caroline Braibant, Secretary-General of i2a shared that whilst the consultants’ conclusion that ATO should NOT be restricted under RoHS was welcomed, the review also indicates that it maymbe reconsidered for restriction in a future review. She stressed how important it is to address this unjustified and unproductive (iterative) preoccupation around ATO.
The chairmen of i2a, Hans Vercammen (Campine) and Raymond Devaux (AMG Antimony), also strongly disagree with the second part of this conclusion, as the risk of using ATO in EEE has not been demonstrated, and none of the four conditions in Article 6 of RoHS to be restricted are met by ATO:
a) ATO does not have a negative impact during EEE waste management operations; the consultants actually recognize the ATO brings an advantage!
b) ATO does not give rise to uncontrolled or diffuse release into the environment of the substance;
c) ATO does NOT lead to unacceptable exposure of workers involved in the waste EEE collection or treatment processes. Appropriate OEL values are in place: these apply in producing, converting and recycling facilities.
d) ATO cannot be fully replaced by substitutes or alternative technologies which have less negative impacts in all applications. Various users of ATO, such as the manufacturers of combustion engine and equipment, home
appliance, semiconductors, as well as of medical and/or test & measurement industrial devices, have furthermore insisted on the high-performance and high reliability competitiveness of ATO compared to potential alternatives.
In addition to continuing its evidence generation to counter ‘political’ statements with sound scientific arguments, i2a is also contributing to the 2021 EU RoHS Directive review through the umbrella association Eurometaux. RoHS is and should continue to be a system which restricts
chemicals that pose real risks when used and present in EEE.