RoHS is here—with 29 exemptions, and counting

By John F. Mason, Contributing Writer -- Electronic Business, 9/12/2006

RoHS and WEEE are now law in most of the European Union’s 25 countries. Although some extensions have been granted to nations for WEEE compliance, all products sold in Europe after the July 1, 2006, deadline must adhere to the Restriction on Hazardous Substances (RoHS), which bans the use of certain materials in electronic products.

However, “Twenty-nine exemptions to the RoHS directive have been granted by the European Commission, with 80 more being considered,” says James Lovegrove, managing director of AeA Europe, a nonprofit high-tech trade group for companies based in the United States.

Companies apply for exemptions when they find it difficult or impossible to manufacture RoHS-compliant products as efficiently or effectively as they could before the ban. Companies prove the validity of their request by comparing the performance of their products using banned substances with those using their substitutes. The requests are studied and approved or disapproved by the EU Commission.

Of the 29 exemptions (see list below), nine (No. 21–29) were still not published in the EU’s Official Journal as of mid-August, because the validity of the requests and their importance are still being assessed.

“The two biggest challenges to the RoHS law are being posed by the elimination of lead and cadmium,” says Geoffrey Bock, an engineer with TUV Rheinland of Germany and North America (a compliance consultancy and auditor). “The characteristics of nonlead solder are so different from those of lead solder that companies using substitutes are having difficulty creating electronic parts with solders that can withstand extreme temperatures or vibrations. Additionally, one substitute, tin, has a whiskering problem.

“The cadmium problem is showing up in products where cadmium was used to increase the reliability or speed of an electronic part. Now that RoHS bans it, companies are trying to discover new alternatives,” Bock says.

Besides lead and cadmium, the importance of other banned substances depends on the manufacturer’s product. For some, mercury has been essential; for others, it was never required.

29 exemptions to the RoHS directive

Exempt by the EU Commission from the RoHS directive are the following substances and, in some cases, the amount that can be used of each:

1. Mercury in compact fluorescent lamps, not exceeding 5 milligrams per lamp

2. Mercury in straight fluorescent lamps for general purposes, not exceeding 10 mg of halophosphate, 5 mg of triphosphate with a normal lifetime, and 8 mg of triphosphate with a long lifetime

3. Mercury in straight fluorescent lamps for special purposes

4. Mercury in other lamps not specifically mentioned in the EU Directive

5. Lead in glass of cathode ray tubes, electronic components and fluorescent tubes

6. Lead as an alloying element in steel containing up to 0.35 percent lead by weight, aluminum containing up to 0.4 percent lead by weight and copper alloys containing up to 4 percent lead by weight

7. Lead in solders with a high melting temperatures, such as lead-based alloys containing 85 percent or more lead by weight; lead in solders for servers; lead in storage and storage array systems; lead in network infrastructure equipment for switching, signaling, transmission and network management for telecommunications; and lead in electronic ceramic parts, such as piezoelectronic devices

8. Cadmium and its compounds in electrical contacts and cadmium plating, except for applications banned under specific EU directives restricting the marketing and use of certain dangerous substances and preparations

9. Hexavalent chromium to prevent corrosion of carbon-steel cooling systems in absorption refrigerators, and DecaBDE (a flame retardant) in polymeric applications

10. Lead in shells and bushes bearing lead-bronze

11. Lead used in compliant pin connector systems

12. Lead as a coating material for thermal conduction module c-rings

13. Lead and cadmium in optical and filter glass

14. Lead in solders consisting of more than two elements for the connection between the pins and the package of microprocessors with a lead content of more than 80 percent and less than 85 percent by weight

15. Lead in solders to complete a viable electrical connection between the semiconductor die and the carrier within integrated-circuit flip-chip packages

16. Lead in linear incandescent lamps with silicate-coated tubes

17. Lead halide as a radiant agent in high-intensity-discharge lamps used for professional reprography applications

18. Lead as an activator in the fluorescent powder (1 percent lead by weight or less) of discharge lamps when used as suntanning lamps or as speciality lamps for diazo-printing reprography, lithography, insect traps or photochemical or curing processes

19. Lead with PbBiSn-Hg (lead-bismuth-tin-mercury) or PbInSn-Hg (lead-Indium-tin-mercury) in specific compositions as the main amalgam and with PbSn-Hg (lead-bismuth-mercury) as the auxiliary amalgam in very compact energy-saving lamps

20. Lead oxide in glass used for bonding the front and rear substrates of flat fluorescent lamps used for liquid crystal displays

21. Lead and cadmium in printing inks for the application of enamels on borosilicate glass

22. Lead as an impurity in RIG (rare earth iron garnet) Faraday rotators for fiber optic communications systems

23. Lead in finishes of fine-pitch components other than connectors with a pitch of 0.65 millimeters or less with NiFe lead frames and lead in finishes of fine-pitch components other than connectors with a pitch of 0.65 mm or less with copper-lead frames

24. Lead in solders for the soldering of machined through-hole discoidal and planar array ceramic multilayer capacitors

25. Lead oxide in plasma display panels and surface conduction electron emitter displays used in structural elements, notably in the front and rear glass dielectric layer, the bus electrode, the black stripe, the address electrode, the barrier ribs, the seal frit and the frit ring, as well as in print pastes

26.Lead oxide in the glass envelope of black-light blue lamps

27. Lead alloys as solder for transducers used in high-power loudspeakers (designed to operate for several hours at acoustic power levels of 125 decibels SPL [sound pressure level] and above)

28. Hexavalent chromium in corrosion-prevention coatings of unpainted metal sheetings and fasteners used for corrosion protection and electromagnetic interference shielding in equipment falling under a specific EU Directive covering IT and telecommunications equipment (exemption granted until July 1, 2007)

29. Lead bound in crystal glass as defined in a specific EU Directive