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SAFEGUARDS | Electrical & Electronics NO. 142/16

SafeGuardS landscape lamp

On June 27th 2016, Oeko-Institut and Fraunhofer Institute IZM publically released their assessment report of “pack 9” Exemptions. On July 20 2016, 34+ global industry associations formally responded to the consultants recommendations. The repose is titled RoHS “Pack 9” Exemptions Assessment Report - Umbrella Project Initial Feedback. [1]

EU RoHS Pack 9 Exemption Assessment Report Umbrella Projects Initial Feedback - Summary Highlights

In May 2016 we have informed you [2] about RoHS exemptions where no renewal request has been filed. In this SGS- SafeGuardS we would like to introduce highlights of the “umbrella project”. [3] 12 exemptions for renewal and/or rewording are submitted during January 2015. The exemptions submitted were identified as 4(f), 6a, 6b, 6c, 7a, 7(c)I, 7(c)II, 7(c)IV, 8(b), 15, 34, and 37 as given in Directive 2011/65/EU; Annex III.

A summary of the key concerns and recommendations:

  1. Concern – Inclusion of shorter applicability dates
    Recommendation – Additional validity period of 5 years for categories 1 to 7 and 11 of Annex I

  2. Concern – Rewording and or splitting of exemptions

Recommendation – In cases where maintaining the current exemptions or rewording and or splitting them would serve the same purpose, renewal of exemption wording

Please refer to the tables for more information.

Table 1:

Exemption # Current Wording Consultants Recommendation Umbrella Project Recommendation
4(f) Mercury in other discharge lamps for special purposes not specifically mentioned in this Annex

(II) Mercury in high pressure mercury vapour lamps used in projectors where an output ≥2000 lumen ANSI is required
For Cat. 5: 21 July 2021

(III) Mercury in high pressure sodium vapour lamps used for horticulture lighting
For Cat. 5: 21 July 2021

(IV) Mercury in lamps emitting light in the ultraviolet spectrum for curing and disinfection
For Cat. 5: 21 July 2021

Renewal of existing exemption wording
“Mercury in other discharge lamps for special purposes not specifically mentioned in this Annex”
For categories 1 to 7, 10 and 11 of Annex I for an additional validity period of 5 years

6(a) Lead as an alloying element in steel for machining purposes and in galvanised steel containing up to 0,35 % lead by weight

I) Lead as an alloying element in steel for machining purposes containing up to 0,35 % lead by weight
For Cat. 1-7 and 10 and 11: 21 July 2019

II) Lead in batch hot dip galvanized steel components containing up to 0.2% lead by weight
For Cat. 1-7 and 10 and 11: 21 July 2021

Targeted Rewording
“Lead as an alloying element in steel for machining purposes containing up to 0.35% lead by weight and in batch hot dip galvanized steel items containing up to 0.2% lead by weight”
[And, to the extent possible, avoid/limit splitting/renumbering/itemization]
For categories 1 to 7, 10 and 11 of Annex I for an additional validity period of 5 years.

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

Lead as an alloying element in aluminium

I) with a lead content up to 0.4 % by weight, used for the production of parts not machined with shape cutting chipping technologies
For Cat. 1-7 and 10 and 11: 21 July 2021

II) for machining purposes with a lead content up to 0.4 % by weight
For Cat. 1-11: 21 July 2021

Renewal of existing exemption wording
“Lead as an alloying element in aluminium containing up to 0,4 % lead by weight”
For categories 1 to 7, 10 and 11 of Annex I for an additional validity period of 5 years.

6 (c) Copper alloy containing up to 4 % lead by weight Copper alloy containing up to 4% lead by weight
For Cat. 1-7 and 10 and 11: 21 July 2019;

Renewal of existing exemption wording
“Copper alloy containing up to 4 % lead by weight”
[as also proposed by the consultant]
for categories 1 to 7, 10 and 11 of
Annex I for an additional validity period of 5 years

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

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

II) in all applications not addressed in items III and IV, but excluding applications in the scope of exemption 24
For categories 1 to 7 and 10: 21 July 2021

III) for die attach For categories 1 to 7 and 10: 21 July 2019 IV) for electrical connections on or near the voice coil in power transducers
For categories 1 to 7 and 10: 21 July 2019

Renewal of existing exemption wording
“Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead)”
[as also recently implemented by the Commission under ELV4]
for categories 1 to 7, 10 and 11 of Annex I for an additional validity period of 5 years

Table 2:

Exemption # Current Wording Consultants Recommendation Umbrella Project Recommendation
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

7(c)-I: Electrical and electronic components containing lead in a ceramic other than dielectric ceramic in discrete capacitor components, e.g. piezoelectronic devices
For categories 1-7 and 10: 21 July 2019

7(c)-V: Electrical and electronic components containing lead in a glass or in a glass or ceramic matrix compound. This exemption does not cover the use of lead in the scope of exemption 34 (cermet-based trimmer potentiometers).
For categories 1-7 and 10: 21 July 2021

Targeted Rewording
“Electrical and electronic components containing lead in a glass or ceramic other than dielectric ceramic in discrete capacitor components, e.g. piezoelectronic devices, or in a glass or ceramic matrix compound”
for categories 1 to 7, 10 and 11 of Annex I for an additional validity period of 5 years
7(c)-II Lead in dielectric ceramic in capacitors for a rated voltage of 125 V AC or 250 V DC or higher Lead in dielectric ceramic in discrete capacitor components for a rated voltage of 125 V AC or higher, or for a rated voltage of 250 V DC or higher
For Cat. 1-7 and 10: 21 July 2019

Targeted Rewording
“Lead in dielectric ceramic in discrete capacitor components for a rated voltage of 125 V AC or higher, or for a rated voltage of 250 V DC or higher.”
[as also proposed by the consultant]
for categories 1 to 7, 10 and 11 of Annex I for an additional validity period of 5 years

7(c)-IV Lead in PZT based dielectric ceramic materials for capacitors which are part of integrated circuits or discrete semiconductors" Lead in PZT-based dielectric ceramic materials of capacitors being part of integrated circuits or discrete semiconductors
For Cat. 1-7 and 10: 21 July 2019
Renewal of existing exemption wording
“Lead in PZT based dielectric ceramic materials for capacitors which are part of integrated circuits or discrete semiconductors”
for categories 1 to 7, 10 and 11 of Annex I for an additional validity period of 5 years
8(b) Cadmium and its compounds in electrical contacts

8(c): Cadmium and its compounds in electrical contacts of

(I) circuit breakers

(II) thermal motor protectors excluding hermetically sealed thermal motor protectors For Cat. 1-7 and 10: 21 July 2021

(III) thermal sensing controls For Cat. 1-7 and 10: 21 July 2019

(IV) AC switches rated at 6 A and more in combination with 250 V AC and more

(V) AC switches rated at 12 A and more in combination with 125 V AC and more For Cat. 1 to 5, 7 and 10: 21 July 2019

(VI) AC switches for corded tools rated at 6 A and more in combination with 250 V AC and more

(VII) AC switches for corded tools rated at 12 A and more in combination with 125 V AC and more

(VIII) DC switches for cordless tools with a rated current of 20 A and more in combination with at a rated voltage of 18 V DC and more

(IX) switches for tools conceived to be used with power supplies of 200 Hz and more
Applies to Cat. 6 EEE: 21 July 2021

Targeted Rewording
“Cadmium and its compounds in electrical contacts of circuit breakers, thermal sensing controls, thermal motor protectors (excluding hermetic thermal motor protectors), DC switches rated at 20 A at 18 V DC and more, AC switches rated at 6 A 250 V AC - 12 A 125 V AC and more, and switches used at voltage supply frequencies of 200 Hz and more” And, to the extent possible, avoid/limit splitting/renumbering/itemization].
for categories 1 to 7, 10 and 11 of Annex I for an additional validity period of 5 years.

Table 3:

Exemption # Current Wording Consultants Recommendation Umbrella Project Recommendation
15 Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit flip chip packages

II) Lead in solders to complete a viable electrical connection between semiconductor die and the carrier within integrated circuit flip chip packages where one of the below criteria applies:

a) A semiconductor technology node of 90 nm or larger For categories 1-7 and 10: 21 July 2019

b) A single die of 300 mm2 or larger in any semiconductor technology node For categories 1-7 and 10: 21 July 2021

c) Stacked die packages with dies of 300 mm² or larger, or silicon interposers of 300 mm2 or larger
For categories 1-7 and 10: 21 July 2021

Targeted Rewording 
“Lead in solders to complete a viable electrical connection between the semiconductor die and the carrier within integrated circuit flip chip packages where one of the below criteria applies:
- A semiconductor technology node of 90 nm or larger
- A Single Die of 300 mm2 or larger in any semiconductor technology node
- Stacked die packages with die of 300 mm2 or larger, OR silicon interposers of 300 mm2 or larger
- Flip chip on lead-frame (FCOL) packages with a rated current of 3 A or higher and dies smaller than 300 mm²…
And, to the extent possible, avoid/limit splitting/renumbering/itemization]
for categories 1 to 7, 10 and 11 of Annex I for an additional validity period of 5 years.

34 Lead in cermet-based trimmer potentiometer elements Lead in cermet-based trimmer potentiometers
For Cat. 1-7 and 10: 21 July 2019;
Renewal of existing exemption wording
“Lead in the plating layer of high voltage diodes on the basis of a zinc borate glass body”
[as also proposed by the consultant]
for categories 1 to 7, 10 and 11 of Annex I for an additional validity period of 5 years
37 Lead in the plating layer of high voltage diodes on the basis of a zinc borate glass body Lead in the plating layer of high voltage diodes on the basis of a zinc borate glass body
For categories 1-7 and 10: 21 July 2019;

Renewal of existing exemption wording 
“Lead in the plating layer of high voltage diodes on the basis of a zinc borate glass body”
[as also proposed by the consultant]
for categories 1 to 7, 10 and 11 of Annex I for an additional validity period of 5 years

We would like to highlight that above mentioned recommendations are no legal requirements yet but, if found worthy, will be implemented by a renewal of EU RoHS Annex III.

The global footprint of SGS will support you in product compliance with global RoHS (EU, China, Korea, US, etc.), REACH/SVHC, textiles or hard-goods, CPSIA or other toy regulations and many more consumer product related requirements like packaging materials or battery requirements. Regardless if you are in need of chemical testing or services in the fields of inspection, certification, compliance assurance, outsourcing, training or auditing SGS is dedicated to satisfy your needs. Providing service to help your products to be fit for the market requirements of the future – whatever the legal frameworks might be.

For enquiries, please contact:

Kenneth Stanvick
Technical Manager
, Consumer and Retail Services
t: +01 603 305 4103

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