European Commission Seeks RoHS/WEEE Stakeholder Consultation
October 20, 2005
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The European Commission issued a document reflecting a stakeholder consultation on scientific and technical progress under Directive 2002/95/EC of the European Parliament on the restriction of the use of certain hazardous substances in electrical and electronic equipment for the purpose of a possible amendment of the annex.
Written comments are accepted until Oct. 28.
Introduction
Article 4(1) of Directive 2002/95/EC on the restriction of the use of certain hazardous substances in electrical and electronic equipment (1) provides "that from 1 July 2006, new electrical and electronic equipment put on the market does not contain lead, mercury, cadmium, hexavalent chromium, PBB or PBDE." The annex to the Directive lists a limited number of applications of lead, mercury, cadmium and hexavalent chromium, which are exempted from the requirements of Article 4(1).
According to Article 5 (2) of Directive 2002/95/EC, the commission is required to consult relevant stakeholders before amending the annex. The results of this consultation will be forwarded to the Technical Adaptation Committee of the Directive 2002/95/EC and the commission services will provide an account of the information received. Although the commission will analyze the results of the consultation, it is noted that as with all stakeholder consultations, this action is only one part of the decision making process, the commission stressed, adding that neither the fact that a stakeholder consultation is being launched, nor the results of this stakeholder consultation should be interpreted as a political or legal signal that the commission intends to take a given action.
Proposal for Additional Exemptions
Article 5(1)(b) of Directive 2002/95/EC provides that materials and components can be exempted from the substance restrictions contained in Article 4(1) if their elimination or substitution via design changes or materials and components which do not require any of the materials or substances referred to therein is technically or scientifically impracticable, or where the negative environmental, health and/or consumer safety impacts caused by substitution outweigh the environmental, health and/or consumer safety benefits thereof.
On the basis of this provision the commission received from industry additional requests for applications to be exempted from the requirements of the RoHS Directive.
It should be noted that since the wording for some of the exemptions is not self explanatory, some exemption requests may overlap with exemption requests covered by previous consultations. The commission services published the requests as worded by the submitters.
The titles for the exemptions as submitted by industry and the request for exemptions, with the substantiated evidence (available by clicking on the title), are:
- Linear incandescent lamp.
- Mercury in switches.
- Special ICs having tin-lead solder plating on leads used in professional equipment.
- Specific modular units including tin-lead solder being used in special professional equipment.
- Solders containing lead and /or cadmium for specific applications where local temperature is higher than 150 C and which need to work properly more than 500 hours.
- Lead in solder for printed circuit boards for emergency lighting products.
- Hexavalent chromium (Cr-VI) in chromate conversion coatings as surface treatment.
- Lead in gas sensors.
- Concerning of PbO (Lead in Seal Frit) used for making BLU (Back Light Unit) Lam.
- Cadmium in opto-electronic components.
- Non-consumer mechanical power transmission systems including speed reducers and mechanical couplings which rely on electrical/electronic components for safe control and operation.
- Electrical and electronic components contained in heating ventilating and air conditioning building systems, commercial refrigeration systems and transport refrigeration systems.
- Cadmium-bearing copper alloys.
- Electrical/electronic components contained mobile and stationary air compressors and vacuum systems, compressed air contaminant removal systems and pneumatic contractor's air tools.
- Electrical/electronic equipment that is: used in transport - aviation, aerospace, road, maritime, rail; installed into the fabric of buildings - elevators, escalators, moving walks, dumb waiters, and heating, cooling and ventilation systems, and fire and security systems; used in the energy generation and transmission; used in mining and mineral processing; used for non-consumer mechanical power transmission systems; industrial process pumps and compressors; used in industrial refrigeration; and used in military applications.
- Lead alloys as electrical/mechanical solder for transducers used in high-powered professional and commercial loudspeakers.
- Cadmium oxide.
- Solder tin of the thermo fuse with a defined low melting point.
- Lead in lead oxide glass used in plasma display panel (PDP).
- Lead in solder on small PCB and tinned legs of primary components.
- Use of the not lead free component NEC V25 in the Memor 2000.
- Lead used in shielding of radiation for non-medical X-ray equipment.
- Lead based solders sealed or captured within heat-shrinkable components and devices.
Consultation of Interested Parties
In preparation of the decision for the consideration of the items listed above based on Article 5(1) (b), the commission services would like to consult interested parties.
In particular, stakeholders are requested to provide, for each entry, information on:
- The current existence of feasible substitutes in an industrial and/or commercial scale
- Any restrictions that apply to such substitutes.
- The costs and benefits and advantages and disadvantages of such a substitutes.
- Provide a precise wording for each exemption.
Stakeholders are requested to support, as far as possible, their contribution with technical and scientific evidence.
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1. Linear incandescent lamp
- Do feasible substitutes currently exist in an industrial and/or commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages of such substitutes?
- Please indicate a precise wording for this exemption.
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2. Mercury in switches
- Do feasible substitutes currently exist in an industrial and/or commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages of such substitutes?
- Please indicate a precise wording for this exemption.
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3. Special ICs having tin-lead solder plating on leads used in professional equipment
- Do feasible substitutes currently exist in an industrial and/or commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages of such substitutes?
- Please indicate a precise wording for this exemption. |
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4. Specific modular units including tin-lead solder being used in special professional equipment
- Do feasible substitutes currently exist in an industrial and/or commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages of such substitutes?
- Please indicate a precise wording for this exemption. |
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5. Solders containing lead and /or cadmium for specific applications where local temperature is higher than 150 C and which need to work properly more than 500 hours
- Do feasible substitutes currently exist in an industrial and/or commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages of such substitutes?
- Please indicate a precise wording for this exemption.
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6. Lead in solder for printed circuit boards for emergency lighting
- Do feasible substitutes currently exist in an industrial and/or commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages of such substitutes?
- Please indicate a precise wording for this exemption.
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7. Hexavalent chromium (Cr-VI) in chromate conversion coatings as surface treatment
- Do feasible substitutes currently exist in an industrial and/or commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages of such substitutes?
- Please indicate a precise wording for this exemption.
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8. Lead in gas sensors
- Do feasible substitutes currently exist in an industrial and/or commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages of such substitutes?
- Please indicate a precise wording for this exemption.
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9. Concerning of PbO (Lead in Seal Frit) used for making BLU (Back Light Unit) Lamp
- Do feasible substitutes currently exist in an industrial and/or commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages of such substitutes?
- Please indicate a precise wording for this exemption.
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10. Cadmium in opto-electronic components
- Do feasible substitutes currently exist in an industrial and/or commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages of such substitutes?
- Please indicate a precise wording for this exemption.
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11. Non-consumer mechanical power transmission systems including speed reducers and mechanical couplings which rely on electrical/electronic components for safe control and operations
- Do feasible substitutes currently exist in an industrial and/or commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages of such substitutes?
- Please indicate a precise wording for this exemption.
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12. Electrical and electronic components contained in heating ventilating and air conditioning building systems, commercial refrigeration systems and transport refrigeration systems
- Do feasible substitutes currently exist in an industrial and/or commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages of such substitutes?
- Please indicate a precise wording for this exemption.
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13. Cadmium-bearing copper alloys
- Do feasible substitutes currently exist in an industrial and/or commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages of such substitutes?
- Please indicate a precise wording for this exemption.
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14. Electrical/electronic components contained mobile and stationary air compressors and vacuum systems, compressed air contaminant removal systems and pneumatic contractor's air tools
- Do feasible substitutes currently exist in an industrial and/or commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages of such substitutes?
- Please indicate a precise wording for this exemption.
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15. Electrical/electronic equipment that are: used in transport - aviation, aerospace, road, maritime, rail; installed in to the fabric of buildings - elevators, escalators, moving walks, dumb waiters, and heating, cooling and ventilation systems, and fire and security systems; used in the energy generation and transmission; used in mining and mineral processing; used for non-consumer mechanical power transmission systems; industrial process pumps and compressors; used in industrial refrigeration; and used in military applications
- Do feasible substitutes currently exist in an industrial and/or commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages of such substitutes?
- Please indicate a precise wording for this exemption.
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16. Lead alloys as electrical/mechanical solder for transducers used in high-powered professional and commercial loudspeakers
- Do feasible substitutes currently exist in an industrial and/or commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages of such substitutes?
- Please indicate a precise wording for this exemption.
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17. Cadmium oxide
- Do feasible substitutes currently exist in an industrial and/or commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages of such substitutes?
- Please indicate a precise wording for this exemption.
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18. Solder tin of the thermo fuse with a defined low melting point
- Do feasible substitutes currently exist in an industrial and/or commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages of such substitutes?
- Please indicate a precise wording for this exemption.
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19. Lead in lead oxide glass used in plasma display panel (PDP)
- Do feasible substitutes currently exist in an industrial and/or commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages of such substitutes?
- Please indicate a precise wording for this exemption.
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20. Lead in solder on small PCB and tinned legs of primary components
- Do feasible substitutes currently exist in an industrial and/or commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages of such substitutes?
- Please indicate a precise wording for this exemption.
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21. Use of the not lead free component NEC V25 in the Memor 2000
- Do feasible substitutes currently exist in an industrial and/or commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages of such substitutes?
- Please indicate a precise wording for this exemption.
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22. Lead used in shielding of radiation for Non Medical X-ray equipment
- Do feasible substitutes currently exist in an industrial and/or commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages of such substitutes?
- Please indicate a precise wording for this exemption.
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23. Lead-based solders sealed or captured within heat-shrinkable components and devices
- Do feasible substitutes currently exist in an industrial and/or commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages of such substitutes?
- Please indicate a precise wording for this exemption
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Interested parties are invited to send their comments by Oct. 28 by email to ENV-RoHS@cec.eu.int or by post to:
European Commission
DG Environnent, Unit G4 - Consultation Directive 2002/95/EC
B-1049, Brussels, Belgium.
Responses submitted electronically will be posted on the European Commission as they are received, unless respondents specifically request that their contribution should not be publicized. If so, responses should be clearly and visibly marked with the words "Not for publication”.
(1) OJ L 37, 13.2.2003, p. 19
Source: European Commission.