Canadian Chemicals Management Program

Environment Canada’s plan to regulate 200 chemical substances categorized as being potentially harmful to human health and/or the environment.

On June 26, 2010 the Canadian Department of the Environment elected not to ban five rosin-containing substances from all products manufactured and sold in Canada. The Department concluded that the five rosins identified under Batch 10 of the Canadian Chemicals Management Plan are not inherently toxic, bioaccumulative or persistent and, therefore, do not pose a threat to human health or the environment. These substances include: Resin acids and Rosin acids, hydrogenated, esters with pentaerythritol (CAS# 64365-17-9); Rosin, hydrogenated (CAS# 65997-06-0); Resin acids and Rosin acids, hydrogenated, esters with glycerol (CAS# 65997-13-9); Resin acids and Rosin acids, hydrogenated, esters with triethylene glycol (CAS # 68648-53-3); Resin acids and Rosin acids, fumarated, barium salts (CAS# 124751-15-1).

In October 2009, IPC along with its Solder Products Value Council and Environment, Health and Safety Committee submitted comments to the Canadian Department of the Environment with an in-depth analysis of how banning rosins would negatively affect the reliability, functionality and safety of all electronic products.

Rosin is a key ingredient in soldering materials used in the manufacture of over seventy-five percent of electronics products, including sophisticated defense systems and telecommunication and transportation technologies. In the electronics industry, Rosin is used in liquid soldering fluxes, both in the flux medium of solder paste and in the flux core of solder wire, in which it provides the chemical and electrical properties needed for the efficient and reliable assembly of most electronic products. There are no suitable alternatives for Rosin and a ban would negatively affect the reliability and functionality of all electronic products manufactured or sold in Canada.

In its comments to the Department, IPC concluded that due to the unique characteristics of rosins, there are no other chemicals or combination of chemicals known that can provide the same functionality and reliability. Banning rosin would have forced a change in the composition of soldering flux and solder paste that would have ultimately affected the reliability of the final electronic product. IPC’s comments also highlighted the extremely important point that rosins have not been found to cause harm to human health and the environment and, therefore, should not be restricted.

Background
Canada’s Chemicals Management Program is a part of the Canadian Environmental Protection Act of 1999 and is the first chemicals program to categorize chemicals. The ultimate goal of the program is to improve protection against hazardous chemicals. The program involves a variety of measures to ensure the proper management of chemicals: information on proper use and disposal; regulations to restrict and possibly ban chemicals; and a risk-based, science-based approach to chemical assessments. The government has instituted a science-based regulatory system to improve assessment and mitigation of risks to ensure the proper management of chemicals. Every three months, the Canadian government publishes batches of 10-25 substances from the list of 200 chemical substances. Industry and stakeholders will have six months to provide comments once a batch is released on how the Canadian government should proceed forward. The government will take one of the following actions on chemicals once the comment deadline is complete: no action, put the chemical on a Priority Substances List for further assessment, or recommend the chemical be added to the List of Toxic Substances with the possibility of virtual elimination. For more information please visit the Environment Canada website.