RoHS Exemptions - Review of Annex to RoHS Directive: 2017 Consultation



The 6-weeks stakeholder consultation began on 20.10.2017 ended on 01.12.2017. The consultation covered eight exemption requests:

(*) Annex III, Ex. 41Lead in solders and termination finishes of electrical and electronic components and finishes of printed circuit boards used in ignition modules and other electrical and electronic engine control systems, which for technical reasons must be mounted directly on or in the crankcase or cylinder of hand-held combustion engines (classes SH:1, SH:2, SH:3 of Directive 97/68/EC of the European Parliament and of the Council ( 2 ))”

(*) Annex IV, Ex. 37 "Lead in platinized platinum electrodes used for conductivity measurements where at least one of the following conditions applies: (a) wide-range measurements with a conductivity range covering more than 1 order of magnitude (e.g. range between 0,1 mS/m and 5 mS/m) in laboratory applications for unknown concentrations; (b) measurements of solutions where an accuracy of +/– 1 % of the sample range and where high corrosion resistance of the electrode are required for any of the following: (i) solutions with an acidity < pH 1; (ii) solutions with an alkalinity > pH 13; (iii) corrosive solutions containing halogen gas; (c) measurements of conductivities above 100 mS/m that must be performed with portable instruments.

(*) Annex IV, Ex. 41Lead as a thermal stabiliser in polyvinyl chloride (PVC) used as base material in amperometric, potentiometric and conductometric electrochemical sensors which are used in in-vitro diagnostic medical devices for the analysis of blood and other body fluids and body gases."

(*) Request 2017- 3 "Lead in solders of alpha spectrometers, pulse-processing electronics, scintillation detectors and spectroscopy systems used in equipment to identify radiation, expiring on 23 July 2024"

(*) Request 2017- 4 “Lead in solder and hexavalent chromium in parts used to make RF detectors in Mass Spectrometers, to be added to Annex IV”

(*) Request 2017- 5 "Lead in thermal cut-off fuses overmolded into solenoid coils used in industrial monitoring and control instruments (Category 9) and EEE falling under Category 11."

(*) Request 2017- 6 " Bis (2-ethylhexyl) phthalate in rubber parts such as O-rings, seals, vibration dampers, gaskets, hoses, grommets and cap-plugs that are used in engine systems including exhausts and turbochargers that are designed for use in equipment that is not designed solely for consumer use."

(*) Request 2017- 7 "Lead in solders of sensors, actuators and engine control units (ECUs) that are used to monitor and control engine systems including turbochargers and exhaust emission controls of internal combustion engines used in equipment that are not intended to be used solely by consumers."

Two contributions have been made to the consultation:

(*) One contribution was submitted by a European healthcare facility regarding the renewal request for Ex. 41 of Annex IV.

(*) A second contribution was submitted by the Swedish Chemicals Agency and concerns the following exemptions: Ex. 2017-5Ex. 2017-6 and Ex. 2017-7.


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