One June 27, 2016, the Commission posted Oeko-Institut’s report on the bulk of the requests for EU RoHS exemption renewals. The report covers renewal requests for 29 RoHS 2 Annex III exemptions including: no. l(a to e -lighting purpose), no. l(f – special purpose), no. 2(a), no. 2(b)(3), no. 2(b)(4), no. 3, no. 4(a), no. 4(b), no. 4(c), no. 4(e), no. 4(f), no. 5(b), no. 6(a), no. 6(b), no. 6(c), no. 7(a), no. 7(c) – I, no. 7(c) – II, no. 7(c) – IV, no. 8(b), no. 9, no. 15, no. 18b, no. 21, no. 24, no. 29, no. 32, no. 34, no. 37.

In general, all of the exemptions with renewal requests have been recommended for renewal in one form or another; however, several of the exemptions have a narrower scope of allowed use than the current exemption or a short timeframe before expiry for certain applications.  The complete report (all 864 pages) is available on the Commission’s website. A summary table of recommendations is available in the Executive Summary at the front of the report.  We’ve also provided below an excerpt, analysis and discussion of the more commonly used exemptions in EEE products.

Note: the dates in the discussion below focus on product categories 1-7, 10, and 11. The exemption period for category 8 (medical devices) and 9 (monitoring and control instruments) is typically recommended for a longer time given the extra two years provided to these products in the RoHS Directive.

Exemption 6 – Lead in Alloys

The consultant’s recommendations for the lead in alloys exemptions mark the beginning of the end – the Commission’s push to begin phasing out these lead in alloy exemptions wherever possible.  The 6a (lead in steel), 6b (lead in aluminium alloys), and 6c (lead in copper alloys) exemptions are recommended for renewal, but generally with a short three-year duration for most product categories.  Some of the exemptions are also recommended for carving into multiple parts, usually with tighter scope and/or reduced concentration levels.

The renewal applications did not provide a lot of information to distinguish which applications still need the exemption and which don’t; therefore the consultant proposes a three-year timeframe for manufacturers and their supply chain to provide better information to justify longer term exemptions for applications that still need them; the consultants, otherwise recommend that the exemptions are allowed to expire after the three years. This “ultimatum” will certainly cause significant concern within the EEE industry and supply base. The consultants acknowledge that machining and other fabrication processes may need to be modified to accommodate non-lead materials.

Exemption 6a (Lead as an alloying element in steel for machining purposes and in galvanized steel containing up to 0.35% lead by weight) was split up based on application. In particular the allowed concentration level for galvanized steel components has been reduced to 0.2% lead. This exemption is known to be misused in many steel parts, regardless of application and the need for using lead. Separating the exemption based on application may put more visibility and accountability to justify the purpose of the lead in steel.