RG - EU ROHS Exemptions 6a, 6b and 6c

Question Posed:

Have exemptions 6a, 6b and 6c expired or do they have RoHS Exemption renewals?

Answer Provided:

**Article contents valid as of 2017-07-14

These are expected to be renewed.

The OEKO Institute has made the following recommendations to the European Commission on what the renewal should look like.  These recommendations are receiving negative feedback from industry stakeholders. It should also be noted that deadlines to the recommendations can still be updated if industry stakeholder request an extension of the deadline within a suitable time frame.

 

Recommendation for Exemption 6(a):

  • It is recommended to split the exemption and provide different review periods for each entry. A short review period of three years is proposed for applications where lead is present for machining purposes. The overall picture where substitution efforts are promising is not clear enough at present to allow an adjustment of the scope. In parallel it is established that substitutes are practical at least for some applications. The aim of a future review should therefore be to evaluate results of a comprehensive survey of the supply related to the applications of leaded steel alloys together with their technical requirements. The aim should be to check the applicability of a more narrow scope for the exemption. The consultants would further recommend cancelling the exemption, should industry fail to provide detailed and substantiated information in the future. As for the exemption for batch hot dip galvanized steel, a lower threshold is proposed in agreement with the applicant for lead in batch hot dip galvanized steel items and a review period of the maximum permissible validity of five years is proposed for this part of the exemption, as the lead is mostly an unintentional impurity in the galvanizing bath

 

Recommendation for Exemption 6(b):

  • It is recommended to split the exemption. A review period of five years is proposed for the exemption entry on the unintentionally introduced lead, i.e., alloys used for the production of non-machined parts. A short review period of three years is proposed for applications where lead is present for machining purposes. This would allow industry a longer transition period towards substitutes, as well as providing time to apply for new exemptions should substitutes not be comparable in performance for specific applications.

 

Recommendation for Exemption 6(c):

 

  • It can currently not be concluded whether substitution of the use of copper alloys containing lead up to 4% by weight is scientifically or technically practicable. It appears that substitutes can be applied in some cases (lead-free or with lower lead content), however mutual factors that would allow conclusions for specific sub-groups cannot currently be identified. It can also be understood that at least in some cases, available substitutes cannot be applied. The overall picture where substitution efforts are promising is not clear enough at present. The aim of a future review should therefore be an exhaustive inventory on the applications of leaded copper alloys together with their technical requirements in order to check the applicability of a more narrow scope for the exemption. This should also encourage machining process adaptation to be further investigated to process lead-free [and/or reduced lead] alloys. Various stakeholders explain that such a survey would not be practical; however it is the obligation of the applicants (and of stakeholders interested in the exemptions renewal) to provide sufficient information to justify exemptions and their renewal.  Thus, the consultants recommend the renewal of Exemption 6c with the current scope and wording. However to stress the need to set up such an inventory and to start an integrated approach and to initiate a comprehensive survey along the value chain with a view to, at least, identify lists of components or categories of applications for lead reduction or substitution, the consultants propose to set a short review period of three years. As it does not seem that most stakeholders have detailed plans as to how to promote substitution in the future, the consultants would further recommend cancelling the exemption, should industry fail to provide substantiated information in the future.

 

Reference - (OEKO Institute recommendations on EU RoHS exemptions): [http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_9/RoHS-Pack_9_Part_ALLOYS-MISC_06-2016.pdf]

Reference - (List of all EU RoHS exemptions): http://ec.europa.eu/environment/waste/rohs_eee/pdf/Exemptions%20list%20-%20validity%20and%20rolling%20plan_18May%2018_public.xlsx



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