Short answer: in most cases, no. Diboron trioxide (B2O3, CAS 1303-86-2) and lead monoxide (PbO, CAS 1317-36-8) are consumed in the chemical reaction that forms glass and ceramic. Once the material is formed, these precursor substances no longer exist in the finished article. Under the industry position established by JEITA, they are no longer SVHCs present in the article and are not reportable under REACH Article 33. The exception is when the finished ceramic is itself a listed substance, such as lead zirconate titanate. Both cases are covered below, with citations.
What REACH Article 33 requires
Article 33 of the REACH Regulation ((EC) No 1907/2006) requires the supplier of an article containing a Candidate List substance (SVHC) above 0.1% weight by weight to communicate sufficient information for safe use to the recipient, at minimum the name of the substance. Consumers can request the same information and must receive it within 45 days. The obligation is triggered by the presence of the SVHC in the article, at the article level, above the threshold.
The entire question for ceramics and glass therefore turns on one word: presence. Is the SVHC actually in the article?
Why ceramics and glass are UVCB substances
Ceramic and glass are not mixtures of their raw materials. The precursor oxides react during firing or melting: they form a solid solution and then a new material with a complex composition of metal oxides, nitrides, and carbides that cannot be tied to a single defined chemical structure. Glass is amorphous, with no identifiable crystal system. Ceramics do not always have their ingredients in fixed proportions.
Materials like this cannot be identified by a specific CAS number keyed to composition. They are classified as UVCB substances: substances of Unknown or Variable composition, Complex reaction products or Biological materials. The US EPA takes the same view under TSCA, listing ceramic, inorganic glass, and frits in the TSCA inventory as UVCB substances. JEITA's guideline on the identification of ceramic and glass substances in electronic components (Version 3.1, November 2014) concludes that treating ceramic and glass as UVCB substances is the correct approach on the grounds of both toxicity risk assessment and chemical accuracy.
The JEITA position on diboron trioxide
Diboron trioxide was added to the REACH Candidate List in the seventh update, announced June 18, 2012. It is used throughout the electronic components industry as a raw material for the glass and ceramic in protective films, resistive bodies, and electrodes.
JEITA's Electronic Components Board issued a formal position paper on B2O3 (24JEITA-DenBuKi No. 207, December 12, 2012). Its reasoning: the chemical compounds in the raw materials first become a solid solution and then form glass or ceramic, which are UVCB substances. Because diboron trioxide itself is not formed in the glass or ceramic of a finished electronic component, JEITA recommends that suppliers reply "Not Included" to certificates of non-inclusion for SVHCs.
The position paper addresses an apparent contradiction that confuses many compliance reviews. Supplier declarations frequently still list B2O3 as a constituent, because IMDS and similar formats require constituent materials to total 100% and recommend describing UVCB glass by its constituent oxides. JEITA is explicit that this is an identification convention, not a composition claim: the oxides identify the UVCB, but the oxides themselves are not included in it. A declaration listing B2O3 in glass should be interpreted as "not classified as an SVHC substance," and the boron present in the molded article is represented as B2O3 for data-format reasons only.
The JEITA position on lead oxides in ceramic and glass
Lead monoxide (PbO, CAS 1317-36-8), orange lead (Pb3O4, CAS 1314-41-6), and several lead-containing complex oxides were added to the Candidate List in the eighth update, December 19, 2012. The same UVCB logic applies. Where lead oxide is used as a raw material for glass or ceramic, it reacts during formation and is not present as lead oxide in the finished material. Under the JEITA identification rules, it is declared by convention as an oxide identifier, for example:
Lead monoxide [PbO] in glass, CAS 1317-36-8, 40 wt%
with the concentration calculated and expressed in terms of metal oxide content, and the remainder of the material identified as "Glass without declarable substances" or "Ceramic without declarable substances." The "in glass" and "in ceramic" qualifiers carry the UVCB interpretation: the identifier describes what went into the material, not a substance sitting inside the article. Note that RoHS is a separate analysis; lead in glass or ceramic remains subject to RoHS substance restrictions and their exemptions (for example the lead-in-glass and ceramic exemptions of Annex III), which is a different obligation from Article 33 disclosure.
The exception: when the ceramic is itself an SVHC
The eighth Candidate List update also created the case that breaks the general rule. Some lead-containing complex oxides listed as SVHCs are themselves finished ceramic compositions. Lead titanium zirconium oxide (PZT, [(PbxZryTiz)O3], CAS 12626-81-2) is the standard example, widely used in piezoelectric components. Here the SVHC is not a consumed precursor. The ceramic in the article is the listed substance, and the JEITA guideline directs that it be identified and its concentration declared according to the legal provisions:
Lead titanium zirconium oxide [(PbxZryTiz)O3], CAS 12626-81-2, 85 wt%
An article containing PZT above 0.1% w/w carries the full Article 33 communication duty. Any blanket statement that lead compounds in ceramic are never reportable is wrong, and a declaration process that cannot distinguish the two cases will produce both false disclosures and missed ones.
What this means for your Article 33 report
The practical rule set, applied per substance and per application:
- Precursor oxide consumed in forming the UVCB (B2O3 in sealing glass, PbO in glass frit): not present in the article, not reportable under Article 33. A "Not Included" reply to an SVHC certificate is the JEITA-recommended response.
- Oxide identifier appearing on a supplier declaration with an "in glass" or "in ceramic" qualifier: an identification convention for the UVCB, interpreted as not classified as an SVHC.
- Ceramic that is itself a Candidate List substance (PZT and similar complex oxides): reportable, with substance name and concentration declared per the REACH instructions, and the Article 33 duty applies above 0.1% w/w.
- In all cases, the application determines the analysis. The same CAS number is reportable in one use and not in another.
How BOMSync handles UVCB substances
BOMSync applies this rule set automatically. Users define UVCB treatment based on where a substance is used, because the application is paramount: the same CAS number for diboron trioxide is excluded from Article 33 disclosure when it appears as a glass or ceramic constituent, and evaluated normally elsewhere. Declarations using the JEITA oxide-identifier convention are recognized as UVCB identifications rather than composition claims, so they do not generate false SVHC findings. Ceramics that are themselves Candidate List substances, such as PZT, are flagged and reported with substance name and concentration. The UVCB exclusion is applied deterministically at report generation, so every line of the resulting Article 33 disclosure is traceable to a rule and defensible in an audit.
References
- Regulation (EC) No 1907/2006 (REACH), Article 33: Duty to communicate information on substances in articles.
- JEITA Electronic Components Board, Guideline for the Identification of Ceramic and Glass Substances in Electronic Components, Version 3.1, November 2014 (26JEITA-DenBuKi No. 160).
- JEITA Electronic Components Board, About the Industry's Position Relating to Diboron Trioxide (B2O3), Newly Listed in the Seventh SVHC under the EU-REACH Regulation, December 12, 2012 (24JEITA-DenBuKi No. 207).
- ECHA, Guidance for Identification and Naming of Substances under REACH and CLP (ECHA-11-G-10.1-EN), Version 1.2, March 2012.
- ECHA Candidate List of Substances of Very High Concern: diboron trioxide added June 18, 2012 (7th update); lead oxides and lead-containing complex oxides added December 19, 2012 (8th update).