Number

304-EN

Section

General Section

Use

Abstract

DEHP, BBP, and DBP are low molecular weight phthalates used to make cables softer and more flexible. These phthalates have been included in the REACH Candidate List and have been discussed in context of the RoHS recast. In line with the its precautionary principle, Dell has decided to proactively eliminate these phthalates from all of its products. The phthalates have been replaced with Trioctyl Trimellitate (TOM or TOTM) or Dioctyl Terephthalate (DOCP). TOM and DOCP offer the same functionality, however these are neither classified nor labelled and are not CMR substances. Dell has also started to request that its suppliers disclose the use of additional phthalates (DIDP, DNOP, DIBP, DHNUP, DIHP) to enable swift phase out of these as well.

Substituted substances

Alternative Substances

Reliability of information

Evidence of implementation: there is evidence that the solution was implemented and in use at time of publication

Reason substitution

ED

Hazard Assessment

Substances to be substituted: The four phthalates subject to elimination in this case story all have official classifications as being CMR substances and are on the hazardous Substance Database according to SUBSPORTplus Screening Criteria. Di(2-ethylhexyl) phthalate (DEHP) is a Substance of very high concern and is included on the REACH restriction list, according to Article 73 of Regulation (EG) No. 1907/2006. (REACH Regulation). Dibutyl phthalate (DBP) is a Substance of very high concern and is included on the REACH restriction list, according to Article 73 of Regulation (EG) No. 1907/2006. (REACH Regulation). Diisobutyl phthalate (DIBP) is a Substance of very high concern and is included on the REACH restriction list, according to Article 73 of Regulation (EG) No. 1907/2006. (REACH Regulation). Benzyl butyl phthalate (BBP) is a Substance of very high concern and is included on the REACH restriction list, according to Article 73 of Regulation (EG) No. 1907/2006. (REACH Regulation). Alternative substances: The alternatives, trioctyl trimellitate and dioctyl terephthalate do not have any official classification, and are not on the hazardous Substance Database according to SUBSPORTplus Screening Criteria.

Description of Substitution

When designing products, Dell’s commitment is to avoid substances that could seriously harm the environment or human health. That’s why Dell applies the strictest government standards across our product lines, using the European Union’s Restriction on Hazardous Substances (RoHS) directive and Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulations as their global baseline. DEHP, BBP, DBP, and DIBP were included in the REACH Candidate List as substances of very high concern in October 2008. Three of these phthalates (DEHP, BBP, DBP) were also included in Annex III of the proposal of the RoHS recast by the EU Commission as priority substances to be assessed for potential restriction under RoHS. DEHP, BBP, DBP, and DIBP are low molecular weight phthalates used in plastics, predominantly in cables, to make them softer and more flexible. The term low molecular weight phthalates refers to the carbon backbone. In case of the low molecular weight phthalates like DEHP, BBP, DBP, and DIBP, the carbon backbone consists of 3 to 6 carbon atoms in the alcohol chain. Low molecular weight phthalates such as DEHP, BBP, DBP and DIBP are classified as toxic for reproduction and have therefore been included in the REACH Candidate List and are subject to further risk reduction measures. The four phthalates are also subject to authorization under REACH and a sunset date of February 2015 has been set. The phthalates have been substituted with Trioctyl trimellitate (TOM/TOTM) or Dioctyl terephthalate (DOTP), which offer the same functionality. Both TOM/TOTM and DOTP have a high molecular weight and bulky structure and thus a low migration potential. They are not classified or labelled and are not CMR substances and are also not subject to risk reduction. These substances can serve as direct substitutes for the low molecular weight phthalates when used in plastic cables to make them softer and more flexible. It is also fairly unproblematic to source plastic cables with these substitutes, as they are readily available in the quantities used by Dell in all of their applications. The substitution is also helped by the fact that the conversion is to a large extent cost neutral. Although the name of DOTP may indicate that it is a phthalate, in fact, it is categorised as a phthalate-free substance. Other phthalates have come under scrutiny as well, be it through their ban in toys and childcare articles (1999/815/EC) or through additions to the REACH Candidate List. Therefore we started in 2009 to request from suppliers the disclosure of the use (mass and concentration) of additional phthalates (e.g. DIDP, DNOP, DIBP, DHNUP, DIHP) to enable them to swiftly phase them out as well. The restriction on the three phthalates DEHP, BBP, and DBP was effective by July 1, 2010 for all newly launched Dell parts and products and was effective by July 1, 2012 for all Dell sustaining products. The restriction on DIBP will be effective by January 1, 2014 for all newly launched Dell parts and products and will be effective by January 1, 2015 for all Dell sustaining products.

Case/substitution evaluation

This is a case story describing a proactive and stepwise strategy to substitute phthalates of concern with safer alternatives. According to existing classification the alternatives are safer than the eliminated phthalates and according to the user there have been no major technical problems or costs associated with the substitution. A number of widely used phthalates (DEHP, DIBP, BBP, DBP) are on the REACH authorisation list. The concentration of these phthalates in products produced and placed on the market after 7th of July 2020 is limited below 0.1% by weight by a restriction REACH (Annex XVII, entry 51).

State of implementation

Full capacity

Date and place of implementation

2010-2015

Enterprise using the alternative

www.dell.com

Availability ofAlternative

on the market

Type of information supplier

User

Contact

www.dell.com

Date, reviewed

November 26, 2021