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What are the Exemptions for RoHS?

Directive 2002/95/EC - RoHS
Decision 2010/571/EU
Corrigendum 2010/571/EU
Decision 2011/534/EU

Exemptions to RoHS are granted to narrowly-defined applications for which the elimination of the prohibited substance is technically or scientifically impracticable or when the only available substitution produces more negative than positive benefits to the environment, health, or consumer safety. 

Exemptions are temporary in nature and subject to review at least every four years, until such time as a reliable and safe substitution is available. For this reason, many exemptions carry an expiration date.

On September 24, 2010, the European Commission adopted a substantially revised list of RoHS exemptions and replaced the entire Annex for clarity. Exemption 39 for cadmium in LEDs is new.  Exemptions 1, 2, 3, 4 5, 7, 8, 11 and 25 were broken into subcategories with more specific definitions and conditions of use. Exemptions 9a, 10, 22, 28 and 35 were deleted because they had expired. Adding to the complexity is the fact that printing errors in the Decision are corrected by a Corrigendum, meaning there is no one document that contains the correctly printed new Annex.

Then on September 8, 2011, the European Commission added Exemptions 7(c)-IV and 40 to the Annex.

More than half of the exemptions have expiration dates (many expired in 2011). Some expiration dates are absolute, some allow reduced amounts of the hazardous substance thereafter, and some allow continued use in spare parts.

1 Mercury in single capped (compact) fluorescent lamps not exceeding:
1a For general lighting purposes < 30 W:  5 mg per burner. 
Expired December
31, 2011
After December 31, 2011:  3.5 mg per burner 
After December 31, 2012:  2.5 mg per burner
1b For general lighting purposes ≥ 30 W and < 50 W:  5 mg per burner
Expired December
31, 2011
After December 31, 2011:  3.5 mg per burner
1c For general lighting purposes ≥ 50 W and < 150 W:  5 mg per burner
1d For general lighting purposes ≥ 150 W:  15 mg per burner
1e For general lighting purposes with circular or square structural shape and tube diameter ≤ 17 mm.  No limit until 2012
After December 31, 2011:  7 mg per burner
1f For special purposes:  5 mg per burner
2a Mercury in double-capped linear fluorescent lamps for general lighting purposes not exceeding:
2a1 Tri-band phosphor with normal lifetime and a tube diameter < 9 mm (T2): 
5 mg per lamp.  Expired December 31, 2011
After December 31, 2011:  4 mg per lamp
2a2 Tri-band phosphor with normal lifetime and a tube diameter ≥ 9 mm
and ≤ 17 mm (T5):  5 mg per lamp.  Expired December 31, 2011
After December 31, 2011:  3 mg per lamp
2a3 Tri-band phosphor with normal lifetime and a tube diameter > 17 mm and ≤ 28 mm (T8):  5 mg per lamp.  Expired December 31, 2011
After December 31, 2011:  3.5 mg per lamp
2a4 Tri-band phosphor with normal lifetime and a tube diameter > 28 mm (T12):  5 mg per lamp.  Expires on December 31, 2012
After December 31, 2012:  3.5 mg per lamp
2a5 Tri-band phosphor with long lifetime (≥ 25 000 h):  8 mg per lamp
Expired December 31, 2011.  After December 31, 2011:  5 mg per lamp
2b Mercury in other fluorescent lamps not exceeding:
2b1 Linear halophosphate lamps with tube > 28 mm (T10 and T12): 
10 mg per lamp       Expires on April 13, 2012
2b2 Non-linear halophosphate lamps (all diameters):  15 mg per lamp
Expires on April 13, 2016
2b3 Non-linear tri-band phosphor lamps with tube diameter > 17 mm (T9)
No limit until 2012. 
After December 31, 2011:  15 mg per lamp
2b4 Lamps for other general lighting and special purposes (induction lamps)
No limit until 2012.  After December 31, 2011: 15 mg per lamp
3 Mercury in cold cathode fluorescent lamps and external electrode fluorescent lamps (CCFL and EEFL) for special purposes not exceeding:
3a Short length (≤ 500 mm).  No limit until 2012
After December 31, 2011:  3.5 mg per lamp
3b Medium length (> 500 mm and ≤ 1,500 mm).  No limit until 2012
After December 31, 2011:  5 mg per lamp
3c Long length (> 1 500 mm).  No limit until 2012
After December 31, 2011:  13 mg per lamp
4a Mercury in other low pressure discharge lamps.  No limit until 2012. 
After December 31, 2011: 15 mg per lamp
4b Mercury in high pressure sodium (vapor) lamps for general lighting purposes in lamps with improved color rendering index Ra > 60 not exceeding:
4b-I P ≤ 155 W.  No limit until 2012.  After December 31, 2011:  30 mg per burner
4b-II 155 W < P ≤ 405 W.  No limit until 2012
After December 31, 2011:  40 mg per burner
4b-III P > 405 W.  No limit until 2012.  After December 31, 2011:  40 mg per burner
4c Mercury in other high pressure sodium (vapor) lamps for general lighting purposes not exceeding:
4c-I P ≤ 155 W.  No limit until 2012.  After December 31, 2011:  25 mg per burner
4c-II 155 W < P ≤ 405 W.  No limit until 2012. 
After December 31, 2011:  30 mg per burner
4c-III P > 405 W.  No limit until 2012.  After December 31, 2011:  40 mg per burner
4d Mercury in high pressure mercury (vapor) lamps (HPMV)
Expires on April 13, 2015
4e Mercury in metal halide lamps (MH)
4f Mercury in other discharge lamps for special purposes not specifically mentioned in this Annex
5a Lead in glass of cathode ray tubes
5b Lead in glass of fluorescent tubes not exceeding 0.2 % by weight
6a Lead as an alloying element in steel for machining purposes and in galvanized steel containing up to 0.35 % lead by weight
6b Lead as an alloying element in aluminum containing up to 0.4 % lead by weight
6c Copper alloy containing up to 4 % Lead by weight
7a Lead in high melting temperature type solders (lead-based alloys containing 85 % by weight or more lead)
7b Lead in solders for servers, storage and storage array systems, network infrastructure equipment for switching, signaling, transmission, and network management for telecommunications
7c-I Electrical and electronic components containing lead in a glass or ceramic other than dielectric ceramic in capacitors (piezoelectronic devices) or in a glass or ceramic matrix compound
7c-II Lead in dielectric ceramic in capacitors for a rated voltage of 125 V AC or 250 V DC or higher
7c-III Lead in dielectric ceramic in capacitors for a rated voltage of less than 125 V AC or 250 V DC.  Expires on January 1, 2013 
(except spare parts for EEE placed on market before Jan 1, 2013)
7c-IV
new
Lead in PZT-based dielectric ceramic materials for capacitors being part of integrated circuits or discrete semiconductors
8a Cadmium and its compounds in one shot pellet type thermal cut-offs
Expired January 1, 2012
(except spare parts for EEE placed on market before Jan 1, 2012)
8b Cadmium and its compounds in electrical contacts
9 Hexavalent chromium as an anticorrosion agent of the carbon steel cooling system in absorption refrigerators up to 0.75 % by weight in the cooling solution
9b Lead in bearing shells and bushes for refrigerant-containing compressors for heating, ventilation, air conditioning and refrigeration (HVACR) applications
11a Lead used in C-press compliant pin connector systems
Expired September 24, 2010
(except spare parts for EEE placed on market before Sept 24, 2010)
11b Lead used in other than C-press compliant pin connector systems
Expires on January 1, 2013
(except spare parts for EEE placed on market before Jan 1, 2013)
12 Lead as a coating material for the thermal conduction module C-ring
Expired September 24, 2010
(except spare parts for EEE placed on market before Sept 24, 2010)
13a Lead in white glasses used for optical applications
13b Cadmium and lead in filter glasses and glasses used for reflectance standards
14 Lead in solders consisting of more than two elements for the connection between pins and package of microprocessors with lead content of more than 80% and less than 85% by weight.  Expired January 1, 2011
(except spare parts for EEE placed on market before Jan
1, 2011)
15 Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit flip chip packages 
16 Lead in linear incandescent lamps with silicate coated tubes
Expires on September
1, 2013
17 Lead halide as radiant agent in high intensity discharge (HID) lamps 
used for professional reprography applications
18a Lead as activator in the fluorescent powder (1 % lead by weight or less) of discharge lamps when used as specialty lamps for diazoprinting reprography, lithography, insect traps, photochemical and curing processes containing phosphors such as SMS.  Expired January 1, 2011
18b Lead as activator in the fluorescent powder (1 % lead by weight or less) of discharge lamps when used as sun tanning lamps containing phosphors such as BSP
19 Lead with PbBiSn-Hg and PbInSn-Hg in specific compositions as main amalgam and with PbSn-Hg as auxiliary amalgam in very compact energy saving lamps (ESL).  Expired June 1, 2011
20 Lead oxide in glass used for bonding front & rear substrates of flat fluorescent lamps used for liquid crystal displays (LCD) Expired June 1, 2011
21 Lead and cadmium in printing inks for the application of enamels on glasses, such as borosilicate and soda lime glasses
23 Lead in finishes of fine pitch components other than connectors
with a pitch of 0.65 mm and less.  Expired September 24, 2010
(except spare parts for EEE placed on market before Sept 24, 2010)
24 Lead in solders for the soldering to machined through hole discoidal or planar array ceramic multilayer capacitors
25 Lead oxide in surface conduction electron emitter displays (SED) used in structural elements, notably in the seal frit and frit ring
26 Lead oxide in the glass envelope of black light blue lamps
Expired June 1,  2011
27 Lead alloys as solder for transducers used in high-powered loudspeakers designated to operate for several hours at acoustic power levels of 125 dB SPL and above.  Expired September 24, 2010
29 Lead bound in crystal glass as defined in Annex I (Categories 1, 2, 3, 4) of Directive 69/493/EEC
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 (used for liquid crystal displays, design or industrial lighting)
32 Lead oxide in seal frit used for making window assemblies for Argon and Krypton laser tubes
33 Lead in solders for the soldering of thin copper wires of 100 m diameter and less in power transformers
34 Lead in cermet-based trimmer potentiometer elements
36 Mercury used as a cathode sputtering inhibitor in DC plasma displays with a content up to 30 mg per display.  Expired July 1, 2010
37 Lead in the plating layer of high voltage diodes on the basis of a zinc borate glass body
38 Cadmium and cadmium oxide in thick film pastes used on aluminum bonded beryllium oxide
39 Cadmium in color converting II-VI LEDs (< 10 μg Cd per mm2 of light-emitting area) for use in solid state illumination or display systems
Expires on July 1, 2014
40
new
Cadmium in photoresistors for analogue optocouplers applied in professional audio equipment.  Expires on Dec 31, 2013

This summary of RoHS exemptions is designed to provide you with an accurate, easy-to-understand overview of the topic and does not constitute legal advice. The actual standard in the original language should be reviewed and used for all business, legal, and product compliance purposes.

RSJ provides a number of RoHS compliance services that can be tailored to the needs of your company. We provide awareness training, BOM scrub, compliance program implementation, compliance software evaluation, product risk assessment, as well as RoHS reporting services. We are here to help you!
 
 

 

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