Since July 1, 2006 when the EU RoHS Directive first came into effect, the electronics industry has relied on exemptions that allow restricted substances to be used in specific materials or parts within a RoHS compliant product. Some of these exemptions are commonly used; if fact, most complex electronic products will claim at least a few exemptions. However, many of the exemptions that do not have a fixed expiry date begin to expire in less than two years. Work groups set up by industry associations and major manufacturers are hard at work to develop proposals to renew many of these exemptions, but some of the exemptions may be allowed to expire. Manufacturers and suppliers should be aware of the industry dynamics and to plan accordingly.
RoHS 2 (EU Directive 2011/65/EU) article 5(2) states that the exemptions have a maximum validity period of five years for product categories 1-7 and 10 and 11 (seven years for medical devices and monitoring and control instruments). The current five year validity period (July 22, 2011 to July 21, 2016) applies to the use of exemptions (that have no expiry date) by products in categories 1-7 and 10. The exemptions are not valid after July 21, 2016; that is, unless an application to renew the exemption is successful.
A renewal request (with technical justification) must be submitted no later than 18 months before the exemption expires – that is by January 22, 2015.
Annex III exemptions that are used broadly in electronic components and systems include:
* 6(a), 6(b), and 6(c) that allow specified max. levels of lead (Pb) to be used in iron, aluminum and copper alloys;
* 7(a) Lead in high melting temperature type solders (i.e. lead-based alloys containing 85% by weight or more lead);
* 7(c)-I, 7(c)-II, and 7(c)-IV which allow Lead in various glass and ceramic applications (including certain capacitors)
* 8(b) Cadmium in contacts
* Several exemptions for lead and cadmium in glass for certain optical and filter applications
* 15 lead in solder for flip chip die attach
Products with fluorescent lamps will likely be using one of the mercury exemptions.
Lead in Solder for Communication Products and Servers
For communications equipment and servers, exemption 7(b) “Lead in solders for servers, storage and storage array systems, network infrastructure equipment for switching, signaling, transmission, and network management for telecommunications” is still used by many manufacturers, particularly for complex printed circuit boards using large BGA devices. Significant work has been underway during the past decade to develop new materials and techniques to improve the long-term reliability using Pb-free solders. Many of the major manufacturers have been progressively shifting their designs to Pb-free components and Pb-free soldering processes. It appears that the industry (especially large OEMs) feel that this exemption may no longer be required and it may be time to allow the exemption to expire.
What to do
Product OEMs and suppliers should ensure that they are aware of the exemptions being used in their products and monitor efforts by industry to submit renewal requests for these exemptions. The opportunity to submit a renewal request ends 18 months before the expiry date. There will likely be a few surprises and some re-design work required. Manufacturers that are using any of the specialized exemptions should ensure that someone within the industry has taken responsibility for drafting and submitting the request.