EU Renews RoHS Exemptions for Lead, Cadmium Applications, Adds New One for Lead Application

On 5 February 2019 ten new directives were published in the EU Official Journal amending Annex III to Directive 2011/65/EU (RoHS) regarding the renewal of nine existing exemptions and the addition of one exemption for lead in new uses. The new provisions take effect on 25 February 2019.

Verisk 3E Review            

Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment (ROHS 2) restricts the use of lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE) in electrical and electronic equipment. However, the applications listed in Annexes III and IV of RoHS 2 are exempted from these restrictions. Under Article 5 of RoHS 2 the European Commission must ensure that the exemptions contained in the annexes are adapted to scientific and technical progress.

On 16 November 2018 all ten Commission Delegated Directives were adopted by the EU Commission.

Nine of them extend existing exemptions listed in Annex III of RoHS 2 for the use of lead, lead oxide, and/or cadmium in the specified applications:

• Lead in dielectric ceramic in certain capacitors
• Lead in PZT based dielectric ceramic materials for certain capacitors
• Cadmium and its compounds in electrical contacts
• Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit flip chip packages
• Lead and cadmium in printing inks for the application of enamels on glasses
• Lead bound in crystal glass
• Lead oxide in seal frit used for making window assemblies for certain laser tubes
• Lead in the plating layer of certain diodes
• Lead as activator in the fluorescent powder of discharge lamps containing phosphors

The final directive adds an exemption for lead in bearings and bushes of diesel or gaseous fuel powered internal combustion engines applied in non-road professional use equipment.

For all directives EU member states must adopt a national act transposing them no later than 21 July 2019. They must be applied starting 22 July 2019.

Verisk 3E Analysis          

Manufacturers and distributors of electrical and electronic equipment and their supply chains should note that one exemption for lead is being added, as well as nine exemptions renewed to the RoHS restrictions in relation to lead and cadmium. Potentially affected companies should review the exemptions contained in these new directives to establish whether their operations will be impacted by the changes.