RoHS exemptions are
undoubtedly one of the most hotly debated topics surrounding the RoHS
Directive for two main reasons.
Firstly, the categories of product
considered to fall within the scope of the legislation are very broad -
it is impossible to list every conceivable product that must comply, so
the available guidance is often very generic in nature and occasionally
ambiguous. Secondly, the European Court of Justice, the only legal body
able to provide an authoritative ruling on RoHS, has yet to judge a test
case for 'grey area' equipment - no one really knows precisely what may
be regarded as 'in' or 'out'.
Status on
the Review of RoHS Exemptions
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First Consultation:
Proposed RoHS exemptions agreed by the Technical
Committee on the 10th December 2004. It still requires
approval by the EU Commision. The further exemptions are:
- Lead used in
compliant-pin VHDM (Very High Density Medium) connector
system
- Lead as a coating
material for a thermal conduction module c-ring
- Lead and cadmium in
optical and filter glass
- Lead in optical
transceivers for industrial applications
- Lead in solders
consisting of more than two elements for the connection
between the pins and the package of microprocessors with a
lead content of more than 85% in proportion to the tin-lead
content (exemption until 2010)
- Lead in high
melting temperature type solders (i.e. tin-lead solder
alloys containing more than 85% lead) and any lower melting
temperature solder required to be used with high melting
temperature solder to complete a viable electrical
connection
- Lead in solders to
complete a viable electrical connection internal to certain
Integrated Circuit Packages (Flip Chips) (exemption until
2010)
- Article 4(1)
substances in safety equipment for fire and rescue services.
- Lead in lead-bronze
bearing-shells and bushes.
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Second Consultation:
Proposed new exemptions under review. All inputs to be in by
11/02/2005. The proposed new exemptions are:
- Lead in tin whisker
resistant coatings for fine pitch applications,
- Lead bound in glass,
crystal glass, lead crystal or full lead crystal in general,
- Chromium (also in
oxidation state (VI)) and Cadmium as colouring batch
addition each form up to a content of 2 % in glass, crystal
glass, lead crystal or full lead crystal used as decorative
and / or functional part of electric or electronic
equipment,
- Solders containing lead
and/or cadmium for specific applications,
- Hexavalent chromium (CRVI)
passivation coatings,
- Lead in lead oxide glass
plasma display panels,
- Lead in connectors,
flexible printed circuits, flexible flat cables,
- Lead oxide in lead glass,
bonding materials of magnetic heads and magnetic heads,
- Cadmium as doping
material in avalanche photodiodes (APDs) for the optical
fiber communication systems,
- Lead in optical
isolators,
- Lead in sheath heater of
Microwaves,
- Cadmium pigments except
for applications banned under Directive 91/338/EEC amending
Directive 76/769/EEC relating to the restriction on the
marketing and use of certain substances,
- High Intensity Discharge
(HID) lamps for professional U.V. applications, containing
lead halide as radiant agent,
- Discharge lamps for
special purposes containing lead as activator in the
fluorescent powder (1% lead by weight or less),
- Discharge lamps
containing lead in the form of an amalgam,
- Mercury free flat panel
lamp,
- Special purposes Black
Light Blue (BLB) lamps, containing lead in the glass
envelope,
- Low melting point alloys
containing lead,
- Galvanised steel
containing up to 0.35% lead by weight and aluminium with an
unintended lead content up to 0.4% lead by weight in
electrical and electronic equipment,
- Lead in solder and
hexavalent chromium in surface treatment, in parts recovered
from production printers and copying equipment, sold, rented
or leased or otherwise returned from professional users
other than private households, originally put on the market
before 1 July 2006, and reused for the same purpose within
the original manufacturer's closed loop system until 1 July
2011. In this context a closed loop system means a system
whereby the equipment remains the property of the
manufacturer or is subject to other contractual arrangements
and is returned to the manufacturer either when the contract
expires or at end of life,
- Cadmium sulphide
photocells,
- Applications of lead,
mercury, cadmium, hexavalent chromium, PBBs and PBDEs in
electrical and electronic equipment in the aeronautic and
aerospace sectors that requires high safety standards.
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