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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) 2019/169, (EU) 2019/170, (EU) 2019/171. (EU) 2019/172. (EU) 2019/173. (EU) 2019/174, (EU) 2019/175, (EU) 2019/176, (EU) 2019/177, and (EU) 2019/178 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.

The exemption updates in Annex III are listed in the adjacent tables.

Table 1: Updated exemptions in Commission Delegated Directive (EU) 2019/169

Exemptions Scope & Dates of Applicability 
7(c)-II 

Lead in dielectric ceramic in capacitors for a rated voltage of 125V AC or 250V DC or higher

Does not apply to applications covered by point 7(c)-I and 7(c)-IV of this Annex; expires on:

  • 21 July 2021 for categories 1-7 and 10;
    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
                                                           

Table 2: Updated exemption in Commission Delegated Directive (EU) 2019/170

Exemptions Scope & Dates of Applicability
7(c)-IV

Lead in dielectric ceramic in capacitors for a rated voltage of 125V AC or 250V DC or higher

Lead in PZT based dielectric ceramic materials for capacitors which are part of integrated circuits or discrete semiconductors. Expires on:

  • 21 July 2021 for categories 1-7 and 10; 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
                             

Table 3: Updated exemptions in Commission Delegated Directive (EU) 2019/171

Exemptions Scope & Dates of Applicability
8(b)

Cadmium and its compounds in electrical contacts

Applies to categories 8, 9 and 11 and 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
8(b)-I 

Cadmium and its compounds in electrical contacts used in:

  • Circuit breakers;
  • Thermal sensing controls;
  • Thermal motor protectors (excluding hermetic thermal motor protectors);
  • AC switches rated at 6A and more at 250V AC and more, or 12A and more at 125V AC and more;
  • DC switches rated at 20A and more at 18V DC and more;
  • Switches for use at voltage supply frequency ≥ 200 Hz
Applies to categories 1 to 7 and 10 and expires on 21 July 2021 
                                                               

Table 4: Updated exemptions in Commission Delegated Directive (EU) 2019/172

Exemptions Scope & Dates of Applicability
15 Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit flip chip packages

Applies to categories 8, 9 and 11 and 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
15(a)

Lead in solders to complete a viable electrical connection between the semiconductor die and carrier within integrated circuit flip chip packages where at least one of the following criteria applies:

  • a semiconductor technology node of 90nm or larger;
  • a single die of 300mm2 or larger in any semiconductor technology node;
  • stacked die packages with die of 300mm2 or larger, or silicon interposers of 300mm2 or larger
Applies to categories 1 to 7 and 10 and expires on 21 July 2021
                                               

Table 5: Updated exemptions in Commission Delegated Directive (EU) 2019/173

Exemptions Scope & Dates of Applicability
21 Lead and cadmium in printing inks for the application of enamels on glasses, such as borosilicate and soda lime glasses

Applies to categories 8, 9 and 11 and 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
21(a)

Cadmium when used in colour printed glass to provide filtering functions, used as a component in lighting applications installed in displays and control panels of EEE

Applies to categories 1 to 7 and 10 except applications covered by entry 21(b) or entry 39 and expires on 21 July 2021
21(b)  Cadmium in printing inks for the application of enamels on glasses, such as borosilicate and soda lime glasses Applies to categories 1 to 7 and 10 except applications covered by entry 21(a) or 39 and expires on 21 July 2021 
21(c)  Lead in printing inks for the application of enamels on other than borosilicate glasses  Applies to categories 1 to 7 and 10 and expires on 21 July 2021 
                                                                                                               

Table 6: Updated exemptions in Commission Delegated Directive (EU) 2019/174 to Directive (EU) 2019/176

Exemptions Scope & Dates of Applicability
29

Directive (EU) 2019/174:
Lead bound in crystal glass as defined in Annex I (Categories 1, 2, 3 and 4) of Council Directive 69/493/EEC

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




32 Directive (EU) 2019/175:
Lead oxide in seal frit used for making window assemblies for Argon and Krypton laser tubes
37 Directive (EU) 2019/176:
Lead in the plating layer of high voltage diodes on the basis of a zinc borate glass body
                                                     

Table 7: Updated exemptions in Commission Delegated Directive (EU) 2019/177

Exemptions Scope & Dates of Applicability
18(b)

Lead as activator in the fluorescent powder (1% lead by weight or less) of discharge lamps when used as sun tanning lamps containing phosphors such as BSP (BaSi2O5:Pb)

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
18(b)-I

Lead as activator in the fluorescent powder (1% lead by weight or less) of discharge lamps containing phosphors such as BSP (BaSi2O5:Pb) when used in medical phototherapy equipment

Applies to categories 5 and 8, excluding applications covered by entry 34 of Annex IV, and expires on 21 July 2021
                                               

Table 8: Updated exemptions in Commission Delegated Directive (EU) 2019/178

Exemptions Scope & Dates of Applicability
42

Lead in bearings and bushes of diesel or gaseous fuel powered internal combustion engines applied in non-road professional use equipment:

  • with engine total displacement ≥ 15 litres; or
  • with engine total displacement < 15 litres and the engine is designed to operate in applications where the time between signal to start and full load is required to be less than 10 seconds; or regular maintenance is typically performed in a harsh and dirty outdoor environment, such as mining, construction, and agriculture applications

Applies to category 11, excluding applications covered by entry 6(c) of this Annex.  Expires on 21 July 2024

                                       

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