RoHS Exemption 6(c) and "Less Than or Equal To"

Question:

Should products be considered as compliant with exemption 6(c) if the Lead contained in the product is exactly at 4%?

Answer Provided:

The term "up to" is used to say that something is less than or equal to, but not more than, a stated value, number, or level.  Therefore 4% should still be compliant with the exemption.

Article valid as of 2019-01-14.

References: [https://www.assentcompliance.com/wp-content/uploads/Guide-RoHS-Exemption-List-PC-GD-180717.pdf]

[http://ec.europa.eu/environment/waste/rohs_eee/pdf/Exemptions%20list%20-%20validity%20and%20rolling%20plan_18May%2018_public.xlsx]