The seven EU RoHS exemption renewals that the European Commission posted in March for Parliamentary scrutiny were formally published in the European journal on May 18th. The exemptions include: 6a, 6b, 6c, 7a, 7c-I, 24, and 34. The Commission has provided a transition period of just over a year, with the new exemptions coming into effect on July 1, 2019.
The new exemptions are excerpted in Table 1.
Table 1: RoHS Exemption Renewals Adopted
| Exemption Index | Exemption description | Scope and dates of applicability | Status |
|---|---|---|---|
| 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. | Published |
| 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 | Expires on 21 July 2021 for categories 1-7 and 10. | Published |
| 6(b) | Lead as an alloying element in aluminium containing up to 0,4 % 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. | Published |
| 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 | Expires on 21 July 2021 for categories 1-7 and 10. | Published |
| 6(b)-II | Lead as an alloying element in aluminium for machining purposes with a lead content up to 0,4 % by weight | Expires on 18 May 2021 for categories 1-7 and 10. | Published |
| 6(c) | Copper alloy containing up to 4 % lead by weight | Expires on: − 21 July 2021 for categories 1-7 and 10; − 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. | Published |
| 7(a) | Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead) | Applies to categories 1-7 and 10 (except applications covered by point 24 of this Annex) and expires on 21 July 2021. For categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments expires on 21 July 2021. For category 8 in vitro diagnostic medical devices expires on 21 July 2023. For category 9 industrial monitoring and control instruments, and for category 11 expires on 21 July 2024. | Published |
| 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 | Applies to categories 1-7 and 10 (except applications covered under point 34) and expires on 21 July 2021. For categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments expires on 21 July 2021. For category 8 in vitro diagnostic medical devices expires on 21 July 2023. For category 9 industrial monitoring and control instruments, and for category 11 expires on 21 July 2024. | Published |
| 24 | Lead in solders for the soldering to machined through hole discoidal and planar array ceramic multilayer capacitors | Applies to all categories; expires on: − 21 July 2021 for categories 1-7 and 10; − 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. | Published |
| 34 | Lead in cermet-based trimmer potentiometer elements | Applies to all categories; expires on: − 21 July 2021 for categories 1-7 and 10; − 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. | Published |
Impact on EEE Manufacturers
Most of the exemptions are renewed for the full five years for product categories 1-7 and 10 (starting with the original expiry date of July 21, 2016 until July 21, 2021) with a few exceptions:
- Exemption 6a) lead in steel alloy has a reduced scope — the lead in batch hot dip galvanised steel components has been reduced to 0.2% by weight.
- In exemption 6(b)-II, the use of lead in aluminium for machining purposes expires on 18 May 2021 (three years from the date of publication). The European Commission is signalling that it intends to sunset the use of lead in aluminum, except where the lead content comes from recycled aluminum scrap.
Note that for product categories 8 and 9, the original exemption wording remains in effect for the full seven years from when that product category came into scope of the RoHS substance restrictions. This is July 21, 2024 for industrial monitoring and control instruments.