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Oeko-Institut Announces RoHS Exemption Renewal Request Project (Pack 22)


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The Oeko-Institut has started a new RoHS project which will assess multiple RoHS exemption renewal requests. The assessment will involve a technical and scientific review on whether the renewal requests are justified based on Article 5(1)(a) of the RoHS Directive.

Article 5(1)(a) provides that materials and components may be exempted from the RoHS substance restrictions if this does not weaken the environmental and health protection of the RoHS Directive and any of the following conditions are fulfilled:

  • The elimination or substitution of the restricted substance is scientifically or technically impracticable.
  • The reliability of the substitutes is not ensured.
  • The total negative environmental, health, and consumer safety impacts caused by the substitution are likely to outweigh the total environmental, health, and consumer safety benefits.

The following Annex III RoHS exemptions will be reviewed:

  • 6(a) “Lead as an alloying element in steel for machining purposes and in galvanized steel containing up to 0.35 % lead by weight.”
  • 6(a)-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.”
  • 6(b) “Lead as an alloying element in aluminum containing up to 0.4 % lead by weight.”
  • 6(b)-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.”
  • 6(b)-II “Lead as an alloying element in aluminum for machining purposes with a lead content up to 0.4 % by weight.”
  • 6(c) “Copper alloy containing up to 4 % lead by weight.”
  • 7(a) “Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead).”
  • 7(c)-I “Electrical and electronic components containing lead in a glass or ceramic other than dielectric ceramic in capacitors, e.g. piezoelectronic devices, or in a glass or ceramic matrix compound.”
  • 7(c)-II “Lead in dielectric ceramic in capacitors for a rated voltage of 125 V AC or 250 V DC or higher.”

The evaluation will be performed in cooperation with the European Commission as well as stakeholders and is scheduled to be concluded July 27, 2021 after which a final report will be published.

You can find out more about Oeko-Institut’s evaluation process by visiting their official website.

Total Parts Plus can help your company keep track of RoHS exemptions, including expiration dates and renewal requests. Reach out to our sales team today for a demonstration of our suite of environmental compliance programs.