As the second part of the RoHS review on scope Oko Institute has looked at the exemptions. Here, expert Dr. Paul Goodman of ERA Technology, best guesses what might well happen when the changes are announced a little later in the year.
Click here for a table covering all of the exemptions.
Directive Decoder
It might just be me, but there feels to be more going on at the minute in the world of legislation than at any time since the pre RoHS days.
So I thought I would provide some brief updates.
Click on the link to find out more about:
The 4 potential restricted substances proposed under "RoHS2"
Timescales for "RoHS2" implementation, restricted substances and exemptions
REACH substances for authorisation
Have a quick look at these articles and bring yourself up-to-date on the latest legislative developments.
Directive Decoder
Several months after the annulment of the DecaBDE exemption entered into force there are still some concerns around the detail.
I have been asked several times if the annulment means that it is not allowed at any level or up to and including the maximum allowable limit of 0.1% in PBB and PBDE?
The European Commission is a little late in publishing the comprehensive report on exemptions carried out by German based organisation Oko Institute.
Maybe they disagree with the conclusions or it's in the "to do" pile!
Late 2009 now seems unlikely for a decision but 2010 is still a possibility if they donot delay too long.
Industry wants to know how long the period of grace will be before the changes to exemptions enter into force.
It is believed that Oko is suggesting 18 months in some cases.
That sounds good to me as I am still receiving letters about the short notice decaBDE annulment last summer.
Directive Decoder
The European Commission has published a report, by its technical consultants Oko Institute and Fraunhofer IZM, on 29 current RoHS exemptions.
21 exemptions will be continued, many with amended wording providing greater clarity, with proposed expiration dates between 2010 and 2014.
5 exemptions will be eliminated with transition periods until mid 2011. These are:
The European Commission has amended the Annex to the RoHS Directive with six more to add to the 32 that currently sit within Annex 5 of the so called "RoHS2" proposals.
6 new exemptions have been added to the scope of the RoHS Directive.
For a full, comprehensive listing of numbers 1 to 38 click here.
Directive Decoder
Several people have asked me recently about the status on RoHS exemptions.
You may remember that on 23 March 2009 the Okö Institute and Fraunhofer IZM, private consultants hired by the European Commission (EC), released a report on their evaluation and assessment of existing and new requests for exemptions under the RoHS Directive.
They reviewed twenty nine exemptions and recommended that seven should not be continued.
They also evaluated five requests for new exemptions and they proposed the addition of one, declined one and were unable to make recommendations on the other three.
The consultants were also tasked with providing clearer and unambiguous wording on existing exemptions.
So, almost a year on, where are we now?
The European Commission has published a decision to exempt the use of cadmium in certain colour-converting LED screens from a ban under the RoHS Directive.
Decission 2010/122/EU of 25 February finds that, technically, no suitable alternative has been found.
This will be exemption 39 for use in solid state illumination or display systems and will run until 1 July 2014.
The applicant for the exemption is 3M and it is for a new type of LED that is not yet on the market other than in sample quantities.
Potential future applications will include lighting (white LEDs), projectors (beamers) including small handheld devices and possibly even mobile phones.
The exemption has been published in the Official Journal and is therefore in effect now.
Directive Decoder
With thanks to Dr. Paul Goodman, Cobham Technical Services
The current batch of RoHS exemptions was reviewed in 2008. After a lengthy delay I understand that the TAC (Technical Adaptation Committee) will carry out a postal vote in the next few weeks. Any changes, and several are expected, will enter into force as soon as they hit the OJ (Official Journal) later this year.
While on the subject of exemptions the Council of Ministers is carrying out a review of the exemption proposals that are specific to categories 8 and 9 (medical devices and monitoring and control instruments). Paul Goodman of Cobham Technical Services, who carried out the original review a few years ago, commented that due to the time lag, it is possible that not all of the original recommendations will still be required.
Directive Decoder
Our consultants ERA Technology, trading as Cobham Technical Services has kindly provided details of the revised RoHS exemption list.
The European Commission is consulting (from 20 September until 15 November) on whether or not to extend the exemptions from a ban on hazardous substances in electrical and electronic equipment under the RoHS Directive.
Two relate to lead and the third to cadmium:
Exemption 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"
After a delay of several months the proposed list of RoHS exemptions was finally added to the Official Journal (OJ) of the European Union on 24 September and became effiective on that date (some Member States need to amend their national legislation first).
Continue reading "RoHS exemptions on the OJ and enter force" »
After a lengthy delay the updated list of RoHS exemptions entered into force on 24 September. However, there were errors and a revised list was published on 29 September (see link):
Directive Decoder
A stakeholder consultation has been launched, to run until February, on two RoHS exemption requests.
They cover cadmium used as a pigment for use in vitreous enamel and a restriction on a previous exemption (1) to read non-liquid mercury only.
Directive Decoder
2011 will witness several changes to the list of RoHS exemptions.
Exemptions 19, 20 and 21 will expire on 1 June.
Until 31 December there had been no limitation of use on 1a, 1b, 1e, 2a1, 2a2, 2a3, 2a5, 2b3, 2b4, 3a, 3b, 3c, 4a, 4b1, 4b2, 4b3, 4c1, 4c2, 4c3.
However, after that date, new stricter maximum values / restriction enter into force.
Many exemptions have expiry dates and so will automatically expire unless a request for an extension or renewal is made an agreed.
The current list of exemptions is attached
Directive Decoder
The European Commission has added two new entries to the RoHS exemptions list.
The annex to RoHS directive 2002/95/EC is amended with the addition of:
7(c)-IV...Lead in PZT based dielectric ceramic materials for capacitors being part of integrated circuits or discrete semiconductors
40...Cadmium in photo resisters for analogue optocouplers applied in professional audio equipment.
In January 2013 Directive 2002/95/EC will be replaced by Directive 2011/65/EU (RoHS recast) and exemptions will automatically expire after 5 or 7 years unless renewed.
For the full, revised list of RoHS exemptions see below:
Directive Decoder
This page contains an archive of all entries posted to Directive Decoder in the Exemptions category. They are listed from oldest to newest.
EuP is the previous category.
Exhibitions is the next category.
Many more can be found on the main index page or by looking through the archives.
