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EU intended to amend RoHS 2 lead exemptions

October, 2017

The European Commission (EC) proposed to amend eight lead exemptions in Annex III of RoHS 2 Directive. The draft texts were submitted to the World Trade Organization1-8 on 25 September 2017. Once the drafts are finalised, it will be published in the Official Journal of the European Union (OJEU).

RoHS 2 Directive9 restricts the use of certain hazardous substances in electrical and electronic equipment. Lead, cadmium, mercury, chromium VI, polybrominated biphenyls, and polybrominated diphenyl ethers are regulated. Restriction of four phthalates will be applied from 22 July 2019 or later. Annexes III and IV to RoHS 2 list the exempted materials and components for specific applications. As per the Directive, the exemptions can be added, renewed, amended and revoked.

The upcoming amendments cover a wide range of materials and components e.g. alloys, glass, ceramic, etc. These exemptions were expired on 21 July 2016 for categories 1 to 7. The EC received renewal applications and triggered the review processing. These exemptions can still be applied until the EC made the final decision. The detailed amendment and corresponding expiratory dates can be found in Table 1.

Table 1. Draft RoHS 2 lead exemptions to Annex III.

 Exemption No. Exempted application Category Expiratory date
Lead as an alloying element in steel (EU/509)1
 6(a) Lead as an alloying element in steel for machining purposes and in galvanised steel containing up to 0.35 % lead by weight  

Categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments

21 July 2021 
Category 8 in vitro diagnostic medical devices 21 July 2023
Category 9 industrial monitoring and control instruments and category 11 21 July 2024
 6(a)-I Lead as an alloying element in steel for machining purposes containing up to 0.35% lead by weight and in batch hot dip galvanised steel components containing up to 0.2% lead by weight Categories 1-7 and 10 21 July 2021
 Lead as an alloying element in aluminium (EU/510)2
 6(b)

Lead as an alloying element in aluminium containing up to 0,4 % lead by weight

 

Categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments

21 July 2021
Category 8 in vitro diagnostic medical devices 21 July 2023
Category 9 industrial monitoring and control instruments and category 11 21 July 2024 
6(b)-I

Lead as an alloying element in aluminium containing up to 0,4 % lead by weight, provided it stems from lead-bearing aluminium scrap recycling

Categories 1-7 and 10 

21 July 2021

6(b)-II

Lead as an alloying element in aluminium for machining purposes with a lead content up to 0,4 % by weight

Categories 1-7 and 10

3 years after the OJEU publication

 

Lead as an alloying element in copper (EU/511)3 

6(c)

Copper alloy containing up to 4 % lead by weight


 

 

Categories 1-7 and 10

21 July 2021

Categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments 

 

21 July 2021

Category 8 in vitro diagnostic medical devices

 

21 July 2023

 Category 9 industrial monitoring and control instruments and category 11  

21 July 2024

 Lead in high melting temperature type solders (EU/512)4
 7(a)

Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead)


Categories 1-7 and 10 (except applications covered by point 24 of this Annex III – i.e. lead in solders for the soldering to machined through hole discoidal and planar array ceramic multilayer capacitors)   

21 July 2021

    Categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments  

21 July 2021

    Category 8 in vitro diagnostic medical devices  

21 July 2023

     

Category 9 industrial monitoring and control instruments and category 11

21 July 2024
Lead in glass or ceramic (EU/513)5

7(c)-I

Electrical and electronic components containing lead in a glass or ceramic other than dielectric ceramic in capacitors, e.g. piezoelectronic devices, or in a glass or ceramic matrix compound 

Categories 1-7 and 10 (except applications covered under point 34 of Annex III – i.e. lead in cermet-based trimmer potentiometer elements

21 July 2021 

Categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments;

21 July 2021 

Category 8 in vitro diagnostic medical devices

21 July 2023
Category 9 industrial monitoring and control instruments and category 11 21 July 2024
Lead as activator in the fluorescent powder of discharge lamps containing phosphors (EU/514)6
18(b)

Lead as activator in the fluorescent powder (1% lead by weight or less) of discharge lamps when used as sun tanning lamps containing phosphors such as BSP (BaSi2O5:Pb)

Categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments

21 July 2021
Category 8 in vitro diagnostic medical devices  21 July 2023
Category 9 industrial monitoring and control instruments and category 11 21 July 2024
18(b)-I Lead as activator in the fluorescent powder (1 % lead by weight or less) of discharge lamps containing phosphors such as BSP (BaSi2O5:Pb), when used in tanning equipment or in medical phototherapy equipment - excluding applications covered under point 34 of Annex IV Category 5

21 July 2021

Lead in solders for the soldering to machined through hole discoidal and planar array ceramic multilayer capacitors (EU/515)7
24 Lead in solders for the soldering to machined through hole discoidal and planar array ceramic multilayer capacitors Categories 1-7 and 10 21 July 2021 

Categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring  and control instruments

21 July 2021
Category 8 in vitro diagnostic medical devices 21 July 2023
Category 9 industrial monitoring and control instruments and category 11 21 July 2024
Lead in cermet-based trimmer potentiometer elements (EU/516)8
34

Lead in cermet-based trimmer potentiometer elements

Categories 1-7 and 10 21 July 2021

Categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments

21 July 2021
Category 8 in vitro diagnostic medical devices 21 July 2023
Category 9 industrial monitoring and control instruments and category 11  21 July 2024

[1] G/TBT/N/EU/509 – Lead as an alloying element in steel
[2] G/TBT/N/EU/510 - Lead as an alloying element in aluminium
[3] G/TBT/N/EU/511 - lead as an alloying element in copper
[4] G/TBT/N/EU/512 - lead in high melting temperature solders
[5] G/TBT/N/EU/513 - lead in glass or ceramic
[6] G/TBT/N/EU/514 -  lead as activator in the fluorescent powder of discharge lamps containing phosphors
[7] G/TBT/N/EU/515 - lead in solders for the soldering to machined through hole discoidal and planar array ceramic multilayer capacitors
[8] G/TBT/N/EU/516 -  lead in cermet-based trimmer potentiometer elements
[9] Consolidated version of RoHS 2 Directive

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