RoHS Exemptions: > 2022 CD QD Follow-up Study

Results of direct consultation with stakeholders performed as part of the 2022 “RoHS CD QD Follow-up Study“

Oeko-Institut e.V. has been requested by DG Environment of the European Commission to provide technical and scientific support in a review of cadmium (Cd) quantum dot (QD) applications. Such applications were subject of an assessment of exemptions performed as Pack 15 Task 5 “Assessing three exemption requests for the use of cadmium in quantum dot applications in displays and lighting”, finalised in 2020 and published in January 2021 (European Commission. Directorate General for Environment. et al. 2021). The following three requested exemptions were assessed at the time (the previous consultation page can be accessed here, including the applications and related documents):

Request 2018-1: "Cadmium (<1000 ppm) in luminescent material for on-chip application on LED semiconductor chips for use in lighting applications of at least CRI 80"

Annex III, Ex. 39a: "Cadmium selenide in downshifting cadmium-based semiconductor nanocrystal quantum dots for use in display lighting applications (< 0,2 μg Cd per mm2 of display screen area)"

Annex III, Ex. 39a: "Cadmium selenide in downshifting cadmium-based semiconductor nanocrystal quantum dots for use in display lighting applications (< 0,1 μg Cd per mm2 of display screen area)"

A decision of the Commission on the fate of these exemptions is still pending. Oeko-Institut has been requested to review the current state of scientific and technical progress of Cd QDs in lighting and display applications. This review should include the comparative status of possible Cd-free substitutes for such applications, to consider if exemptions for Cd in these applications are still justified under the RoHS 2 regime.

The assessment covers technical aspects mentioned in the study request specifications. In this respect, for the past exemption requests the assessment should, among others:

Update the analysis presented in the previous study, as regards the alternative technologies to quantum dots and their applications which are currently available on the market, and assess their environmental, health and consumer safety benefits; technical as well as economic information on the current market availability of quantum dots should also be included.
Give additional information on the current LED market, in view of the availability of cadmium free quantum dots with comparable performance as the requested cadmium quantum dots.
Evaluate the end-of-life stage of display and lighting applications; and
Investigate whether the energy efficiency of cadmium containing quantum dot applications would outweigh the negative impacts caused by substitution.

In agreement with the European Commission, no online consultation was carried out as part of this study, but only targeted consultation. This was related to the short time frame of the study, furthermore relevant stakeholders were known to both the EU Commission and the consultant from previous assessments.

To allow involvement of additional stakeholders who were not initially involved in the previous assessments, the specific project website was used to inform stakeholders of the launch of the study and to request those interested in expressing their views to contact the consultants. In addition, stakeholders who had provided contributions to the previous assessment were also contacted directly, requesting a contribution be made and including a questionnaire providing some background information on the study and focussing questions.

Contributions made by stakeholders have been posted online and can be viewed below:

> AM OSRAM

>> Answers to study questionnaire

>> Additional file: Input Exemption Methodology 20200505

>> Additional file: Data sheet Bridgelux

>> Additional file: Data sheet OSCONIQ...

>> Additional file: Data sheet Samsung

> LightingEurope

>> Answers to study questionnaire

>> Additional file 1

> Nanoco, file

> Nanosys, file