RoHS: Using Non-Compliant Material for Repairs

Question: My company purchases bare boards to connect coils and caps together to make cable replacements. One of our subcontractors keeps a stock of this board on hand for repairs, but the company has identified a 0.18 percentage of lead (Pb) in some of the backstock. Can we use a component that is not RoHS-compliant for the repair and service of units sold before July 22, 2019 throughout the transition period of 10 years?

Answer: Category 11 “Other” electronics with the July 22, 2019 compliance date can use non-compliant parts to upgrade or repair product equipment placed on the market before the due date or coming into force date, so it depends upon both the specific substance and its category of electrical and electronic equipment (EEE).

For Category 3 “IT equipment,” lead in components above the 0.1 percent threshold may only be used to repair or upgrade equipment placed on the market before July 1, 2006, unless using a specific application exemption (e.g. lead in high melting point solder). Meanwhile, the deadline for Category 8 “medical devices” is July 22, 2014.

The other complicating factor is whether the use of the lead or other restricted substances is subject to or benefits from one of the specific exemptions, in which case the exemption’s sunset date could apply.

In summary, the substance in question, the product category under which the equipment falls, the relevant date and exemptions all may impact this decision. In your case, usage of the products is compliant, provided the details in your question are accurate.

Content current as of 2019-10-25.

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