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New Set of Exemptions under EU RoHS Law Published, Which Could Assist Hong Kong Exporters of Electrical and Electronic Equipment

On 18 May 2018, the Official Journal of the EU published seven new directives, each of them amending framework Directive 2011/65/EU on the restriction of hazardous substances in electrical and electronic equipment (commonly referred to as RoHS 2). Hong Kong sellers of such products will know that RoHS 2 restricts several hazardous substances in electrical and electronic equipment (EEE), including lead, mercury and cadmium.

The seven new directives amend Annex III of the framework RoHS Directive. Annex III sets out a list of exemptions to the general ban on the use of the hazardous substances. The amendments will allow Hong Kong’s electronic goods exporters to benefit from these specific new exempted applications in the case of lead. The seven newly published directives set out the following exempted applications:

Commission Delegated Directive 2018/736: This Directive renews the exemption for certain electrical and electronic components containing lead in glass or ceramic which was provided for in point 7(c)-I of Annex III until 21 July 2016. The exemption is renewed on the basis that there is still no possibility of substitution or elimination of lead in glass and/or ceramic.

In Annex III to RoHS 2, point 7(c)-I is replaced by the following: “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”.

Commission Delegated Directive 2018/737: Point 24 of Annex III to RoHS 2 exempted the use of lead in solders for “the soldering to machined through hole discoidal and planar array ceramic multilayer capacitors” until 21 July 2016. This new Directive renews the exemption as the substitution of lead here is scientifically and technically impracticable.

Thus, in Annex III to RoHS 2, point 24 is replaced with the following: “Lead in solders for the soldering to machined through hole discoidal and planar array ceramic multilayer capacitors”.

Commission Delegated Directive 2018/738: This Directive renews the exemption found in point 34 of Annex III which expired on 21 July 2016 exempting the use of lead in cermet-based trimmer potentiometer elements. The exemption is renewed on the basis that there are currently no reliable lead-free alternatives available so that substitution of lead remains impracticable.

In Annex III to RoHS 2, point 34 is replaced with the following: “Lead in cermet-based trimmer potentiometer elements”.

Commission Delegated Directive 2018/739: This Directive renews the exemption for the use of lead as an alloying element in steel which was provided for in point 6(a) of Annex III until 21 July 2016.

The Directive stipulates that while lead-free steel is available for some specific applications, substitution for the remaining applications is currently scientifically and technically impracticable. Moreover, a further narrowing of the scope of the exemption has proven to be currently unfeasible due to the complexity of the supply chain.

In relation to galvanised steels, it is noted that lead is still necessary only in batch hot dip galvanised steel and in a lower concentration due to progress in technology.

Therefore, in Annex III to RoHS 2, point 6(a) is replaced by the following: “6(a) - Lead as an alloying element in steel for machining purposes and in galvanised steel containing up to 0.35% lead by weight” and “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 galvanised steel components containing up to 0.2% lead by weight”.

Commission Delegated Directive 2018/740: Point 6(b) of Annex III exempted the use of lead as an alloying element in aluminium containing up to 0.4% lead by weight until 21 July 2016. This Directive renews this exemption.

While certain lead-free alternatives are available on the market, the technical practicability and reliability of these alternatives is still unclear and therefore the exemption remains justified. The Directive states that aluminium alloys where lead is not intentionally introduced and aluminium alloys where lead is added to obtain certain properties should be differentiated in the exemption.

In Annex III to RoHS 2, point 6(b) is replaced by the following: “6(b) - Lead as an alloying element in aluminium containing up to 0.4% lead by weight”, “6(b)-I -Lead as an alloying element in aluminium containing up to 0.4% lead by weight, provided it stems from lead-bearing aluminium scrap recycling” and “6(b)-II – Lead as an alloying element in aluminium for machining purposes with a lead content up to 0.4% by weight”.

Commission Delegated Directive 2018/741: This Directive renews the exemption found in point 6(c) of Annex III which expired on 21 July 2016 exempting the use of lead as an alloying element in copper containing up to 4% lead by weight. The exemption is renewed as alternatives which are scientifically or technically practicable have not been identified.

In Annex III to RoHS 2, point 6(c) is replaced by the following: “6(c) Copper alloy containing up to 4% lead by weight”.

Commission Delegated Directive 2018/742: This Directive renews the exemption for lead in high melting temperature solders which was provided for in point 7(a) of Annex III until 21 July 2016 on the basis that there is still no possibility of substitution or elimination. Moreover, it is not possible to narrow the scope of the exemption due to the high diversity of the applications concerned.  

Thus, in Annex III to RoHS 2, point 7(a) is replaced by the following: “Lead in high melting temperature type solders (i.e. lead-based alloys containing 85% by weight or more lead)”.

The seven directives will enter into force on the twentieth day following that of their publication (i.e., following 18 May 2018). They will have to be implemented by Member States by 30 June 2019.

It is advised that Hong Kong producers consult the text of the directives in order to familiarise themselves with the technical details of the new exemptions and the expiry dates which vary both per exemption and application.

Content provided by Picture: HKTDC Research
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