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RoHS Directive (Restriction of the use of certain Hazardous Substances (RoHS)), which refers to directive 2011/65/EU, was published by the European Union (EU) aiming to reduce the amount of hazardous substances used in electrical and electronic products. Since then, several exemptions were granted to specific applications which are scientifically or technically infeasible to be replaced. 
The exemptions of RoHS 2.0 (2011/65/EU) are listed in Annex III and Annex IV. The exemptions in Annex III are suitable for all EEE. Meanwhile, the exemptions in Annex IV are only suitable for medical devices (category 8) and monitoring and control instruments (category 9). 

Recently, the Official Journal of the European Union has published (EU) 2018/736, (EU) 2018/737, (EU) 2018/738. (EU) 2018/739. (EU) 2018/740. (EU) 2018/741 and (EU) 2018/742 to amend the Annex III of 2011/65/EU. The directives shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union, and will be implemented on 1 July, 2019.

Table 1: Updated exemptions in Commission Delegated Directive (EU) 2018/739 

Exemptions  Scope & Dates of Applicability 
6(a)  Lead as an alloying element in steel for machining purposes and in galvanised steel containing up to 0,35 % lead by weight, 

Applies to categories 8, 9 and 11; expires on:

  • 21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments
  • 21 July 2023 for category 8 in vitro diagnostic medical devices,
  • 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11
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, 

Applies to categories 1-7 and 10; expires on:

  • 21 July 2021
                               

Table 2: Updated exemption in Commission Delegated Directive (EU) 2018/740 

Exemptions Scope & Dates of Applicability
6(b) Lead as an alloying element in aluminium containing up to 0.4 % lead by weight

Applies to categories 8, 9 and 11; expires on:

  • 21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments,
  • 21 July 2023 for category 8 in vitro diagnostic medical devices,
  • 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11
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

Applies to categories 1-7 and 10; expires on:

  • 21 July 2021
 6(b) - II Lead as an alloying element in aluminium for machining purposes with a lead content up to 0,4 % by weight 

Applies to categories 1-7 and 10; expires on:

  • 18 May 2021

                              

Table 3: Updated exemptions in Commission Delegated Directive (EU) 2018/741

Exemptions  Scopes & Dates of Applicability 
6(c) Copper alloy containing up to 4% lead by weight  

Applies to all categories; expires on:

  • 21 July 2021 for category 1-7 and 10
  • 21 July 2021 for category 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments
  • 21 July 2023 for category 8 in vitro diagnostic medical devices
  • 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11
                                                   

Table 4: Updated exemptions in Commission Delegated Directive (EU) 2018/742

Exemptions Scopes & Dates of Applicability
7(a) Lead in high melting temperature type solder (i.e. lead-based alloys containing 85% by weight or more lead)

Applies to all categories; expires on:

  • 21 July 2021 for categories 1-7 and 10 (except applications covered by point 24)
  • 21 July 2021 for category 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments,
  • 21 July 2023 for category 8 in vitro diagnostic medical devices,
  • 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11
                      

Table 5: Updated exemptions in Commission Delegated Directive (EU) 2018/736

Exemptions Scopes & Dates of Applicability
7(c) - I 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

Applies to all categories; expires on:

  • 21 July 2021 for categories 1-7 and 10 (except applications covered under point 34)
  • 21 July 2021 for category 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments
  • 21 July 2023 for category 8 in vitro diagnostic medical devices
  • 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11
         

Table 6: Updated exemptions in Commission Delegated Directive (EU) 2018/737

Exemptions Scopes & Dates of Applicability
24 Lead in solders for the soldering to machined through hole discoidal and planar array ceramic multilayer capacitors

Applies to all categories; expires on:

  • 21 July 2021 for category 1-7 and 10
  • 21 July 2021 for category 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments
  • 21 July 2023 for category 8 in vitro diagnostic medical devices
  • 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11

 

Table 7: Updated exemptions in Commission Delegated Directive (EU) 2018/738

Exemptions Scopes & Dates of Applicability
34 Lead in cermet-based trimmer potentiometer elements

Applies to all categories; expires on:

  • 21 July 2021 for categories 1-7 and 10 (except applications covered by point 24)
  • 21 July 2021 for category 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments,
  • 21 July 2023 for category 8 in vitro diagnostic medical devices,
  • 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11

 

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