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ROHS Simplified
RoHS Simplified - Annexes
   
 

Annex - Specific applications of lead, mercury, cadmium and hexavalent chromium which are currently exempt from the requirements of RoHS. A full list of exemptions, including new and proposed is available here.

1. Mercury in compact fluorescent lamps not exceeding 5mg per lamp.

A compact fluorescent lamp (CFL) is usually defined as a single-ended fluorescent lamp with a bent discharge tube of small diameter, of around 10-16mm, to form a very compact unit. These lamps can be either integral, whereby the lamp and ballast are combined (also known as self-ballasted or selfsupporting), or pin-based.

For the purpose of this exemption, CFLs can contain no more than 5 mg of mercury per lamp.

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2. Mercury in straight fluorescent lamps for general purposes not exceeding:

- 10mg in halophosphate lamps
- 5mg in triphosphate lamps with a normal lifetime
- 8mg in triphosphate lamps with a long lifetime.

A straight, or linear, fluorescent lamp is a fluorescent lamp of straight tubular form and bi-pin electrical connections at either end.

The colour properties of straight fluorescent lamps are determined by the phosphors used to coat the inside of the tube. Halophospate and triphospate are examples of such phosphorous materials.

Straight fluorescent lamps for general purpose can be defined as lamps used for general lighting solutions, in contrast to lamps used for special purposes (see item 3 below).

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3. Mercury in straight fluorescent lamps for special purposes.

Examples of such lamps are black light lamps, disinfection lamps, medical/therapy lamps, pet care lamps (e.g. aquaria lamps), lamps with special components (e.g. integrated reflectors or external protection sleeves), lamps with special ignition features (e.g. designed for low temperatures), long length lamps (length > 1800mm) and amalgam lamps.

In this context, there appears to be no restriction on the use of mercury in these lamps.

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4. Mercury in other lamps not specifically mentioned in this Annex.

Examples of other lamps containing mercury are high intensity discharge (HID) lamps (e.g. sodium lamps and metal halide lamps), circular fluorescent lamps and U-shaped fluorescent lamps.

In this context, there appears to be no restriction on the use of mercury in these lamps.

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5. Lead in glass of cathode ray tubes, electronic components and fluorescent tubes.

Lead, or more specifically lead oxide, is often used in glass for electrical and electronic equipment to obtain specific characteristics, such as radiation protection (CRTs, medical applications), filtering (photography, image processing) and strengthening purposes (e.g. production of fluorescent tubes). This exemption has been introduced because viable alternatives for these applications have not yet been identified.

For clarity, the exemption applies to lead in the glass parts of cathode ray tubes, lead in the glass parts of electronic components and lead in the glass parts of fluorescent tubes. Electronic components in the context of this exemption could
also include glass parts when they are part of an electronic component or electrical and electronic equipment.

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6. Lead as an alloying element in steel containing up to 0.35% lead by weight, aluminium containing up to 0.4% lead by weight and as a copper alloy containing up to 4% lead by weight.

Lead is often used as an alloying element to obtain specific properties of a metal alloy. This exemption applies to the use of lead in steel up to 0.35% by weight, in aluminium up to 0.4% by weight and in copper up to 4% by weight. In the context of this exemption, ‘percentage by weight’ has to be interpreted as ‘the percentage of lead per homogeneous material per discreet part’. For example, if the steel housing of a computer consists of two separate parts, each part can contain up to 0.35% lead by weight of that part.

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7. Lead in high melting temperature type solders (i.e. tin-lead solder alloys containing more than 85% lead).

For the purposes of applications 7, 8 and 9 in this Annex, it is useful to clarify the term ‘solder’. In these Guidance Notes, ‘solder’ is defined as “alloys used to create metallurgical bonds between two or more metal surfaces to achieve an
electrical and/or physical connection”. In this context, the term ‘solder’ also includes all materials that become part of the final solder joint, including solder finishes on components or printed circuit boards.

The high melting temperature type solder exemption has been introduced to allow the use of lead in solders for specific applications (such as in chip manufacturing), for which viable lead-free alternatives have not yet been
identified. The high electrical conductivity and unique mechanical properties of such a high melting point tin-lead alloy make the material malleable and better able to withstand both temperature and physical stress. Such properties ensure fewer defects during manufacturing and high reliability throughout the life of the component, thereby also resulting in fewer components going into the waste
stream.

Since these high melting temperature solders are used in combination with lower melting temperature solders to complete a viable electrical connection (i.e. to properly connect the chip to the semiconductor package), it has been proposed that any lower melting temperature solder required to be used in conjunction with high melting temperature solder should also be considered to fall under this exemption. An assessment of this proposal is included in the review of existing and possible additional exemptions being undertaken by the European Commission and mentioned in the Exemptions section of these Guidance Notes.

 

Lead in solders for servers, storage and storage array systems (exemption granted until 2010).

See definition of ‘solder’ given for application 7 above.

This exemption has been introduced to allow the use of lead in solders for high reliability applications, such as servers, for which viable lead-free alternatives have not yet been identified.

In this context, a ‘server’ is seen as a computer that meets one of the technology criteria that are set out in section (a) below, and the functional criteria set out in section (b) below.

(a) Technology criteria for a server

1) Designed and placed on the market as a Class A product as per EN55022:1994 under the EMC Directive 89/336/EEC (intended primarily for use in the professional environment) and designed and capable of having a single or dual processor capability (one or more sockets on board); or
2) Designed and placed on the market as a Class B product (intended primarily for use in the domestic environment) as per EN55022:1994 under the EMC Directive 89/336/EEC and designed and capable of having at least dual processor capability (two sockets on board).

(b) Functional design criteria for a server

1) Designed and capable of operating in a mission-critical, high-reliability, highavailability application in which use may be 24 hours per day and 7 days per week, and unscheduled downtime is extremely low (minutes per year).

Examples of typical server functions are the provision of network infrastructure, gateway or switching services, the hosting and management of data on behalf of multiple users, or the running of server-capable operating systems (e.g. as for a web server). This exemption is viewed as applying to the whole of the computer and its components including processors, memory boards, power converters, power supplies, enclosed housings, modular power subsystems and adapter cards. It would also seem to apply to the components that are integrated into the whole computer or that are sold separately for use in an exempt server. Cables and cable assemblies, and all connectors and connector assemblies used to provide interconnections for the server, would also be covered.

It should be noted that this exemption is not viewed as applying to parts or components that are peripheral to the server, nor does it apply to parts or components when they are used other than in an exempt server.

For the purpose of the RoHS Regulations, a ‘storage or storage array system’ is viewed as any storage device or subsystem that meets one of the following criteria:

1) Designed and placed on the market as a Class A product as per EN55022:1994 under the EMC Directive 89/336/EEC; or

2) Designed and placed on the market as a Class B product as per EN55022:1994 under the EMC Directive 89/336/EEC and designed to meet one of the following two criteria: -

a) Any storage device capable of accepting direct or switched input from more than one computer, for example fibre channel and SCSI devices, or

b) Any storage fabric or switching device for interconnecting storage devices to server products.

The exemption is viewed as applying to the whole of the device or subsystem. It should be noted that this exemption does not apply to parts or components that are peripheral to the storage or storage array system, nor does it apply to parts or components when they are used other than in an exempt storage or storage array system.

 

Lead in solders for network infrastructure equipment for switching, signaling, transmission as well as network management for telecommunication.

See definition of ‘solder’ given for application 7 above.

This exemption has been introduced to allow the use of lead in solders for high reliability applications, such as network infrastructure equipment, for which viable lead-free alternatives have not yet been identified. In this context network infrastructure equipment for telecommunication purposes is viewed as equipment meeting one or more of the following criteria:

1) Any system used for routing, switching, signalling, transmission, or network management or network security;
2) Any system which can simultaneously enable more than one end user terminating equipment to connect to a network;
3) Any system in a network except for end user terminating equipment such as voice terminals and facsimile machines.

This would appear to include all components, power suppliers, display devices and similar electronic units that are incorporated into network infrastructure equipment. It would also include all cables and cable assemblies, and all
connectors and connector assemblies used to provide interconnections for network infrastructure equipment.

 

Lead in electronic ceramic parts (e.g. piezoelectronic devices). Ceramic materials are used in a variety of electronic devices including capacitors, insulators, piezoelectrics, magnets and integrated circuit packages. Some of these ceramic materials contain lead, for example lead zirconate titanate and lead magnesium niobate. The specific chemical composition and manufacturing process of these materials determine their electrical parameters, such as dielectric constant and the dissipation, that is essential for the functioning of the component in which they are used. Hence, lead used in the ceramic parts of components in electrical and electronic equipment is exempt from these
Regulations.

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8. Cadmium plating except for applications banned under Directive 91/338/EEC (OJ No. L 186, 12 July 1991, p. 59) amending Directive 76/769/EEC (OJ No. L262, 27 September 1976, p. 201) relating to restrictions on the marketing and use of certain dangerous substances and preparations.

Directive 91/338/EEC amending Directive 76/769/EEC relating to restrictions on the marketing and use of certain dangerous substances and preparations, gives the following definition of cadmium plating: “Within the meaning of this Directive, ‘cadmium plating’ means any deposit or coating of metallic cadmium on a metallic surface.” This definition is seen as applying for the purpose of the RoHS Regulations.

Subsequently, the Marketing and Use Directive (as amended) bans the use of cadmium plating in a variety of product sectors. However, that Directive allows the use of cadmium plating for “electrical contacts in any sector of use, on account of the reliability required of the apparatus on which they are installed.”

As a result, in this context cadmium plating is prohibited for products manufactured in the household goods and central heating and air conditioning plant sectors. However, it is viewed as being permitted for electrical contacts in all
the WEEE categories to which the RoHS Regulations apply.

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9. Hexavalent chromium as an anti-corrosion of the carbon steel cooling system in absorption refrigerators.

As absorption cooling works on several different types of energy sources such as gas, kerosene, batteries or electricity, absorption fridges are often used in recreational vehicles (e.g. motor homes and caravans) or remote places where electricity is not available. Another typical application is for minibars in hotel rooms as these fridges are virtually noiseless.

The applied heat and use of a water-ammonia mixture results in a corrosive environment that warrants the use of hexavalent chromium. This exemption has been introduced, since viable alternatives for this specific application have so far not been identified.

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