Industry Associations Response to EU RoHS ‘Pack 9’ Exemption Recommendations

On July 20, 2016, the Cross-industry Project, ‘the Umbrella Project’, released its initial response to recommendations made regarding the Restriction of Hazardous Substances (RoHS) ‘Pack 9’ Exemptions. The recommendations were made by Eunomia Research & Consulting, Oeko-Institut and Frauhofer Institute IZM, following the submission of twelve exemptions for renewal and/or rewording, received by the EU in January 2015.

The Umbrella Project’s response, entitled “RoHS “Pack 9” Exemptions Assessment Report – Umbrella Project Initial Feedback”, collates the opinions of over 34 global industry associations and follows the public release of the consultants’ recommendations on June 27, 2016.

The ‘Umbrella Project’ has initially identified two key areas of concern and has offered recommendations:

1. Concern – Inclusion of shorter applicability dates
Recommendation – Additional validity period of 5 years for categories 1 to 7 and 11 of Annex I

2. Concern – Rewording and or splitting of exemptions
Recommendation – In cases where maintaining the current exemptions or rewording and or splitting them would serve the same purpose, renewal of exemption wording

The twelve exemptions, submitted in January 2015, were identified as 4(f), 6a, 6b, 6c, 7a, 7(c)I, 7(c)II, 7(c)IV, 8(b), 15, 34, and 37, as given in Directive 2011/65/EU; Annex III. These exemptions relate to:

• 4(f) - Mercury in other discharge lamps for special purposes
• 6(a) - Lead as an alloying element in steel for machining purposes and in galvanised steel containing up to 0,35 % lead by weight
• 6 (b) - Lead as an alloying element in aluminium containing up to 0,4 % lead by weight
• 6 (c) - Copper alloy containing up to 4 % lead by weight
• 7 (a) - Lead in high melting temperature type solders (i.e. lead- based alloys containing 85 % by weight or more lead)
• 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
• 7(c)-II - Lead in dielectric ceramic in capacitors for a rated voltage of 125 V AC or 250 V DC or higher
• 7(c)-IV - Lead in PZT based dielectric ceramic materials for capacitors which are part of integrated circuits or discrete semiconductors
• 8(b) - Cadmium and its compounds in electrical contacts

• 15 - Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit flip chip packages
• 34 - Lead in cermet-based trimmer potentiometer elements
• 37 - Lead in the plating layer of high voltage diodes on the basis of a zinc borate glass body

Stakeholders should be aware that these recommendations do not currently hold any legal basis. It is recommended, however, that companies remain informed on the developments to RoHS in order to maintain compliance.

SGS RoHS Services
SGS offers the full-range of inspection, testing, certification, verification and training services. SGS’s global footprint of 28 accredited RoHS laboratories means we can support product compliance with RoHS around the world. Learn more about SGS’s RoHS Services (www.sgs.com/en/consumer-goods-retail/electrical-and-electronics/audio-video-and-household-appliances/rohs)

SGS SafeGuardS keep you up to date with the latest news and developments in the consumer goods industry. Read the full EU RoHS Exemption Assessment Highlights Summary SafeGuardS. (www.sgs.com/en/news/2016/08/safeguards-14216-eu-rohs-exemption-assessment-highlights-summary)

Subscribe here, www.sgs.com/subscribesg, to receive SGS SafeGuardS direct to your inbox.

For further information contact:

Kenneth Stanvick
Technical Manager, EET RSTS
Tel: (+1) 603 305 4103
Email: cts.media@sgs.com
Website: www.sgs.com/ee

About SGS
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This release was published on openPR.