Brief Introduction to EU RoHS as Pack-23 Exemption

The European Union's RoHS (Restriction of Hazardous Substances) directive is a law that limits the use of certain hazardous materials in electronic and electrical equipment. This directive has played a crucial role in protecting the environment and public health by reducing the number of dangerous materials used in electronic devices.

One important aspect of RoHS is the use of exemptions. These exemptions are granted for certain materials or applications in order to support the implementation of the directive and to avoid causing unnecessary harm to the environment or to public health. One such set of exemptions is known as Pack-23 Exemption Recommendations.

Understanding EU RoHS Pack-23 Exemption Recommendations

The recommendation related to lead-in solders applied in certain electronic components, such as those used in aerospace and defense, medical equipment, and high-reliability applications. The EU RoHS exemptions, including 6a, 6b, 6c, 7a, and 7c, are vital in supporting the implementation of the directive and preventing potential harm to the environment or public health.

  • RoHS Exemption 6a applies to "Lead as an alloying element in steel for machining purposes and in galvanized steel containing up to 0,35 % lead by weight".
  • RoHS Exemption 6b applies to "Lead as an alloying element in aluminum containing up to 0,4 % lead by weight"
  • RoHS Exemption 6c applies to "Copper alloy containing up to 4% lead by weight "
  • RoHS Exemption 7a applies to "Lead in high melting temperature type solders (i.e., lead-based alloys containing 85 % by weight or more lead)".
  • RoHS Exemption 7c applies to "Electrical and electronic components containing lead in a glass or ceramic other than dielectric ceramic in capacitors, e.g. piezoelectric devices, or in a glass or ceramic matrix compound"

The main reason for this exemption is that these electronic components are used in critical applications and the replacement of leaded solders with lead-free solders in these applications has been found to be technically unworkable or not suitable due to the higher thermal stress and higher solder joint failure rate, which would compromise the safety and reliability of the products. The exemptions allow the continued use of leaded solder in these applications, provided that certain conditions are met.

It's important to note that these exemptions are not permanent, and they are given an expiration date, known as a sunset date. When an exemption is approaching its expiration date, the industry is able to request that the exemption be renewed or extended beyond its original expiration date. However, this request must be submitted 18 months before the expiration date of the exemption.

The process of renewing an exemption is quite lengthy and involves various steps such as technical and scientific review, consultation with stakeholders, evaluation of technical information, and recommendations on whether to renew, reject or redefine the exemption. The process of renewing an exemption is a lengthy one and can take several years to be completed.

Summary

The EU RoHS Pack-23 Exemption Recommendations are an important aspect of the RoHS directive. They provide a balance between protecting the environment and public health and ensuring that critical applications are not compromised by the restrictions of hazardous materials. EU RoHS exemptions, including 6a, 6b, 6c, 7a, and 7c, play a crucial role in supporting the implementation of the directive and avoiding unnecessary harm to the environment or to public health. It's important to keep track of the expiration dates and renewals of these exemptions to ensure compliance with the RoHS directive. The process of renewing an exemption is a lengthy one and can take several years to be completed.

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