The IEC 62474 ED2 (published November 2018) includes a provision to post and maintain substance exemption lists on the IEC 62474 database. Three lists have been approved so far (see Table 5) and will be posted in March 2019 when the upgraded IEC 62474 database features come on line.
Table 5: Exemptions Lists Approved for Publication on IEC 62474 Database
| Regulatory Basis | List authority | List identity | Initial List version |
|---|---|---|---|
| EU RoHS 2 Annex III (2011/65/EU) | IEC62474 | EU-RoHS-AnnexIII | E1.0 |
| EU RoHS 2 Annex IV (2011/65/EU) | IEC62474 | EU-RoHS-AnnexIV | E1.0 |
| China RoHS 2 | IEC62474 | China-RoHS | E1.0 |
The initial release of the EU RoHS Annex III exemptions will include all of the exemption renewals that were published in 2018 and the additional ten Delegated Directives published in February 2019.
Identification of Exemption Lists
Each exemption list will be identified by the List authority = “IEC62474”, a list identity, and a list version. The list identity will remain fixed for a given regulation and the list version will be revised every time that an edit is made to the list. The list version is in the format Emmm.n where ‘mmm’ represents the major revision number and ‘n’ represents a minor editorial update.
Identification of Exemption Entries
Each exemption entry will also have a unique ID consisting of three parts: a base ID, a version ID, and a sub-exemption identity (explained below). This IEC-ID is intended to uniquely and permanently identify a specific exemption even when a regulation re-uses an exemption number after significantly modifying the technical aspects or scope of an exemption.
The IEC-ID for each entry is of the format “nnnnn-vv-ss”, where nnnnn = base ID number, vv = version (alphabetic), and ss = sub-exemption ID (sub-identity).
Sub-exemptions: Exemption Details that Vary over Time or by Product Category
A unique aspect of the IEC 62474 exemption lists is that exemptions with technical requirements that change over time or have different effective/expiry dates based on product category will be subdivided into sub-exemptions that each have a unique technical requirement, effective date and/or expiry date. Each sub-exemption will share the base ID and version ID of its parent exemption but will have a unique sub-exemption identity (referred to as the sub-identity).
For example, the revised exemption 6(a) that comes into effect on July 1, 2019 is excerpted in Table 6. The example lists three sub-exemptions with different expiry dates for most category 8/9 products, category 8 in vitro, and category 9 industrial. The IEC-IDs for the three sub-exemptions are: 00033-B-01, 00033-B-02, 00033-B-03 – the last two digits indicate the sub-identity. The original exemption as specified in the regulation always has the sub-identity ‘00’.
Table 6: Selected columns for the revised exemption Annex III 6(a)
| IEC-ID | regIndex | Description | Scope and dates of applicability | Effective Date | Expiry Date |
|---|---|---|---|---|---|
| 00033-B-00 | 6(a) | Lead as an alloying element in steel for machining purposes and in galvanised steel containing up to 0.35 % lead by weight | Expires on: − 21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments; − 21 July 2023 for category 8 in vitro diagnostic medical devices; − 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11. | July 1, 2019 | Multiple |
| 00033-B-01 | 6(a) | Lead as an alloying element in steel for machining purposes and in galvanised steel containing up to 0.35 % lead by weight | Expires on: − 21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments; | July 1, 2019 | July 21, 2021 |
| 00033-B-02 | 6(a) | Lead as an alloying element in steel for machining purposes and in galvanised steel containing up to 0.35 % lead by weight | Expires on: − 21 July 2023 for category 8 in vitro diagnostic medical devices; | July 1, 2019 | July 21, 2023 |
| 00033-B-03 | 6(a) | Lead as an alloying element in steel for machining purposes and in galvanised steel containing up to 0.35 % lead by weight | Expires on: − 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11. | July 1, 2019 | July 21, 2024 |
Other Information Included in the Exemption List File
The IEC 62474 exemption lists also provide additional information about each exemption such as the regulatory basis for the exemption and the DSL entry that the exemption applies to. “First Added” and “Last Revised” dates are provided to record when a specific entry was added or changed in the exemption list.
Format of the Exemption Lists (xls vs XML)
The IEC 62474 exemption lists are initially provided only as spreadsheets in xls format but may be migrated to an XML format in the future. The XML format will make it easier for IT systems to automatically import revisions to the exemption list.
Additional Support
For additional support on the exemption lists or in implementing other features associated with the 2nd edition IEC 62474:2018, contact ECD Compliance.