ENVIRO PASS – PRODUCT ENVIRONMENTAL COMPLIANCE
The European Commission has recently updated the EU RoHS exemptions list, a move with significant implications for manufacturers exporting electronics to the European market. The Restriction of Hazardous Substances (RoHS) Directive is a critical piece of EU legislation, but it also recognizes that the immediate elimination of certain hazardous substances is not always technically or scientifically feasible. This is where exemptions play a vital role, providing temporary permission to use a restricted material for a specific application.
Staying current with these exemption updates is crucial for compliance planning. These changes not only set new expiration dates but also introduce new, more specific exemption codes. Understanding the nuances of these updates is essential to avoid supply chain disruption and ensure your products remain compliant.
Importantly, as of July 1st, 2019, the exemptions 6(a) and 6(b), concerning the use of lead in steel and aluminum alloys, will be modified as follows:
| Exemption # | Description | Expiration date |
| 6a | Lead as an alloying element in steel for machining purposes and in galvanized steel containing up to 0.35 % lead by weight | Applies to categories 8 and 9. Expires on: — 21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments; — 21 July 2023 for category 8 in vitro diagnostic medical devices; — 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11. |
| 6a-I | Lead as an alloying element in steel for machining purposes containing up to 0,35 % lead by weight and in batch hot dip galvanized steel components containing up to 0.2 % lead by weight | Applies to categories 1 to 7 and 10. Expires on 21 July 2021 for categories 1-7 and 10. |
| 6b | Lead as an alloying element in aluminum containing up to 0.4 % lead by weight | Applies to categories 8 and 9. Expires on: — 21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments; — 21 July 2023 for category 8 in vitro diagnostic medical devices; — 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11. |
| 6b-I | Lead as an alloying element in aluminum containing up to 0.4 % lead by weight, provided it stems from lead-bearing aluminum scrap recycling | Applies to categories 1 to 7 and 10. Expires on 21 July 2021 for categories 1-7 and 10. |
| 6b-II | Lead as an alloying element in aluminum for machining purposes with a lead content up to 0.4 % by weight | Applies to categories 1 to 7 and 10. Expires on 18 May 2021 for categories 1-7 and 10. |
RoHS product technical files and declarations of conformity will have to be updated accordingly.
Here are further details about EU RoHS requirements: https://www.enviropass.ca/english/eu-rohs/
