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Öko-Institut e.V. Publishes Final Report on Pack 22



The Oeko-Institut has completed it’s review of nine Annex III RoHS exemptions. When considering the extension of certain exemptions, one of three conditions must be met:

  1. Substitution is scientifically or technically impracticable
  2. The reliability of a substitute is not ensured
  3. The negative environmental, health and consumer safety impact of substitution outweigh the benefits thereof.

The institute takes these conditions into consideration when making recommendations. A summary of their recommendations regarding each individual exemption is included below.

  • 6(a) “Lead as an alloying element in steel for machining purposes and in galvanized steel containing up to 0.35 % lead by weight.”

Exemption 6(a) is recommended to expire 21 July 2023 for category 8 and 21 July 2024 for category 9.

  • 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.”

Exemption 6(a)-I is recommended to expire 21 July 2024 for all categories.

The Oeko-Institut has recommended the addition of exemption 6(a)-II: Lead as an alloying element in batch hot dip galvanized steel components containing up to 0.2% lead by weight. The expiration for this exemption is 21 July 2026 for all categories.

  • 6(b) “Lead as an alloying element in aluminum containing up to 0.4 % lead by weight.”

Exemption 6(b) expired in 2019 for categories 1 to 7 and 10 and in 2020 for categories 8 and 9. Category 11 can use exemption 6(b) until 21 July 2024

  • 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.”

This exemption will expire 12 months after the official decision is made for all categories. They have recommended the introduction of exemption 6(b)-III: Lead as an alloying element in aluminium casting alloys containing up to 0.3% lead by weight provided it stems from lead-bearing aluminium scrap recycling. This exemption is set to expire 21 July 2026 for all RoHS categories.

  • 6(b)-II “Lead as an alloying element in aluminum for machining purposes with a lead content up to 0.4 % by weight.”

Exemption 6(b)-II will expire 18 months after the decision for all RoHS categories. The recommended replacement is 6(b)-IV: Lead as an alloying element in aluminium for machining purposes with a lead content up to 0.4% by weight in gas valves applied in category I EEE (large household appliances).

  • 6(c) “Copper alloy containing up to 4 % lead by weight.”

This exemption is recommended to expire on 21 July 2026 for all categories.

  • 7(a) “Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead).”

Exemption 7(a) is recommended to expire for all categories except those specifically outlined 21 July 2024.

  • 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.”

This exemption is set to expire 21 July 2024 for all categories. The recommended replacement is exemption 7(c)-V: Electrical and electronic components containing lead in a glass or glass matrix compound that fulfils the following functions: 1) protection and electrical insulation in glass beads of high voltage diodes and glass layers for wafer on the basis of a lead-zinc borate or a lead-silica-borate glass body,* 2) for hermetic sealings between ceramic, metal and/or glass parts 3) for bonding purposes in a process parameter window for < 500°C combined with a viscosity of 1013,3 dPas (so called “glass transition temperature”) 4) used as resistance materials such as ink, with a resistivity range from 1 Ohms/square to 1 Mega Ohms/square, excluding trimmer potentiometers** 5) used in chemically modified glass surfaces for Microchannel Plates (MCPs), Channel Electron Multipliers (CEMs) and Resistive Glass Products (RGPs). Exemption 7(c)-V is set to expire 21 July 2026 for all categories.

The second recommended exemption for replace is 7(c)-VI: Electrical and electronic components containing lead in a ceramic that fulfils the following functions (excluding items covered under item 7(c)-II, 7(c)-III and 7(c)-IV of this annex): 1) piezoelectric lead zirconium titanate (PZT) ceramics 2) providing ceramics with a positive temperature coefficient (PTC). This exemption is set to expire on 21 July 2026 for all categories.

  • 7(c)-II “Lead in dielectric ceramic in capacitors for a rated voltage of 125 V AC or 250 V DC or higher.”

Exemption 7(c)-II is recommended to expire 21 July 2026 for all categories.

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