Stay in the Know: RoHS Exemptions Analyzed

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Stay in the Know:RoHS Exemptions Analyzed


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Valerie KuntzAssent ComplianceSubject Matter Expert, Materials Management

Today’s Presenter


RoHS Around the World

EU RoHS China RoHS Japan RoHS Korea RoHS India RoHS Norway RoHS (POHS) Turkey RoHS

Concern for the health of citizens and the environment led to the implementation of directives and regulations in countries around the world.

Some examples:


European Union RoHS

Original Directive 2002/95/EC, passed January 27, 2003, restricted six substances with a list of exemptions.

Restricted substances and thresholds: Lead (Pb), (≤ 0.1%) Mercury (Hg), (≤ 0.1%) Cadmium (Cd), (≤ 0.01%) Hexavalent chromium (chromium VI, Cr+6), (≤ 0.1%) Polybrominated biphenyls (PBB), (≤ 0.1%) Polybrominated diphenyl ethers (PBDE), (≤ 0.1%)

Updated Directive 2011/65/EC, passed July 21, 2011, replaced Directive 2002/95/EC. It includes expanded and clarified exemptions.

Works with EU WEEE (Waste Electrical and Electronic Equipment) Directive 2012/19/EU


What is an Exemption?

ExemptionsExemptions temporarily allow a restricted substance to be used in certain applications when a suitable alternative is not currently available.

Exemptions are designed to allow for a gradual phase out of hazardous substances and time to find alternative substances.

Within the Directive, there are two Annexes impacting exemptions:

Annex III, impacting Categories 1 through 11 Annex IV, impacting Categories 8 and 9

Exemption example: “Lead bound in crystal glass as defined in Annex I

(Categories 1, 2, 3, and 4) of Council Directive 69/493/EEC)”


Out of Scope Products vs. Exempted Products

Products of a specific type or category that are allowed to be shipped into the EU without any restrictions on the amount of restricted substance for:

A specific time frame, but will be in scope in the future (Example: industrial monitoring and control instruments)

The foreseeable future (Example: products going into space)

Out of Scope Products:

Exempted Products: Products that meet the requirements of one or more specific

exemptions that can be shipped into the EU with the defined restrictions for a limited time


Exemption Expiration

All exemptions have an expiration date, typically reviewed every 4 years. Expiration dates can vary depending on the final use of the product.

Categories 1 to 7, 10 and 11 have validity period of up to five years

Categories 8 and 9 have validity period of up to seven years

The validity periods are to be decided on a case-by-case basis and may be renewed

Categories 8 and 9 are also broken down further to in vitro medical devices, industrial monitoring and control instruments for which different implementation and expiration dates exist


E.U. Exemption Expiration

Annex III Exemptions:

59 active exemptions (prior to July 21, 2016) 5 expiration dates in the future 46 extension requests (expiration July 21, 2016) 8 will expire (expiration July 21, 2016)

Annex IV Exemptions: 52 active exemptions with expiration dates in the future

Exemptions that have been requested to be extended are still in effect until a decision is reached. The extension is either approved and a new expiration date is assigned, or it is rejected and extended for at least 12 months, and at most, 18 months.

21

JULY


8 Expired Exemptions

5 (a) - Lead in glass of cathode ray tubes 7 (b) - Lead in solders for servers, storage and storage array systems, network infrastructure

equipment for switching, signalling, transmission, and network management for telecommunications

17 - Lead halide as radiant agent in high intensity discharge (HID) lamps used for professional reprography applications

25 - Lead oxide in surface conduction electron emitter displays (SED) used in structural elements, notably in the seal frit and frit ring

30 - Cadmium alloys as electrical/mechanical solder joints to electrical conductors located directly on the voice coil in transducers used in high-powered loudspeakers with sound pressure levels of 100 dB (A) and more

31 - Lead in soldering materials in mercury free flat fluorescent lamps (which, e.g. are used for liquid crystal displays, design or industrial lighting)

33 - Lead in solders for the soldering of thin copper wires of 100 μm diameter and less in power transformers

38 - Cadmium and cadmium oxide in thick film pastes used on aluminium bonded beryllium oxide


Exemption Modifications

The exemption list can be requested to be modified.These modifications can include:

A new extension

Applications related to electrical and electronic equipment (EEE) newly coming into scope

New applications with an aspect of innovation “Old” applications — applications that have either already expired or have been

rejected previously

Change Renewal Removal NOTE: any request for review of an existing exemption can lead to its removal


Exemption List Modification Process Timeline


Future of EU RoHS and Exemptions

RoHS 2.1: Expands the scope of RoHS to an ‘open scope’, impacting all

electrical and electronic equipment, except those specifically excluded in Article 2 (4)

In effect July 22, 2019

RoHS 3.0: Directive (EU) 2015/863, published March 2015 Will add four new substances (DEHP, BBP, DBP and DIBP) to the

restricted list In effect July 22, 2019 for Categories 1-7, 10 and 11, and July 22,

2021 for Categories 8 (medical devices including in vitro medical devices) and 9 (monitoring and control instruments)

Each of these additions will require new exemptions to be defined. These requests will be required to be submitted at least 18 months before the effective dates.


Summary

EU RoHS defined 6 specific substances (10 in the future) that should be restricted above a certain threshold

Exemptions temporarily allow the use of the restricted substances in certain applications

EU RoHS has two different Annexes impacting different categories: Annex III and Annex IV

Exemption list can be modified Process takes approximately 18 months Several exemption extension requests have been

received and are currently under review


Electronic and Electrical Equipment (EEE) in Scope

Electronic and Electrical Equipment Categories:

Category 1 Category 2 Category 3 Category 4 Category 5

Category 6 Category 7 Category 8 Category 9 Category 10 Category 11


[Webinar] Conflict Minerals Benchmarking Study RY 2015 Tuesday, August 2nd | 1PM EDT[Webinar] RoHS Updates Around the World Thursday, August 25th | 1PM EDT

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Date post:	19-Jan-2017
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