RoHS Compliance: Three Exemption Renewals Recommended for Approval

RoHS Compliance: Three Exemption Renewals Recommended for Approval

The Oeko-Institut has released its report summarizing the assessment of three requests for exemption renewals under the Restriction of Hazardous Substances (RoHS) Directive.

The organization is in the middle of its 2015/2016 RoHS Evaluation Project, designed to evaluate exemption renewal requests and provide recommendations to the European Commission. The project breaks exemptions down into groups, called Packs. This report, released on January 21st, provides the Oeko-Institut’s evaluation and recommendations on Pack 7, which includes Exemptions 7b, 9b, 13a and 13b.

The request to renew Exemption 7b was withdrawn by the applicant, leaving only three renewal requests on the table for review. In all three cases, the Oeko-Institut has recommended to the European Commission the exemptions be renewed.

In the case of Exemption 9b, the Oeko-Institut has recommended a change in wording for the purpose of narrowing the exemption’s scope, based upon feedback from the applicant. The recommended exemption would read: Lead in bearing shells and bushes for refrigerant-containing hermetic scroll compressors with a stated electrical power input equal or below 9kW for heating, ventilation, air conditioning and refrigeration (HVACR) applications.

The exemption is recommended to be renewed with this new language and an expiry date of July 21, 2019.

Exemption 13a reads: Lead in white glasses used for optical applications.

Because of the lack of viable alternatives for these uses of lead in white glasses, the Oeko-Institut has recommended the exemption be renewed with the following expirations:

  • Categories 1-7 and 10: July 21, 2021
  • Categories 8 and 9: July 21, 2021
  • Sub-category 8 in-vitro: July 21, 2023
  • Sub-category 9 industrial: July 21, 2024

Exemption 13b has been recommended for renewal based on similar criteria to 13a. Exemption 13b reads: Lead in ion coloured optical filter glass types, or cadmium in striking optical filter glass types, or lead and cadmium in glazes used for reflectance standards, excluding applications falling under point 39 of this annex. Cadmium and lead in filter glasses and glasses used for reflectance standards.

The Oeko-Institut has recommended the exemption be renewed with the same expirations as was recommended for 13a.

The European Commission is not bound to follow the Oeko-Institut’s recommendations. However, precedent has shown they will typically align their decisions with the recommendations in the report.

Exemptions 7a and 15 are up next in the review process.

Exemption 7a reads: Lead in high melting temperature type solders (i.e. lead-based alloys containing 85% by weight or more lead). According to the applicants, this exemption is required due to a lack of viable alternatives. Certain applications for solders containing lead include aerospace and military equipment, and require solders to have a melting point above 300C. The applicants state that more time is needed in order to research, develop and implement a viable, non-lead alternative.

Exemption 15 reads: Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit flip chip packages.

The applicants for this renewal have proposed new wording for the exemption. It reads: Lead in solders to complete a viable electrical connection between active component(s) and the carrier within integrated circuit flip chip packages with at least one of the following characteristics:

  • Greater than or equal to 90nm semiconductor technology node
  • Die size greater than or equal to 300mm2 in any semiconductor technology / node (including stacked die)
  • Stacked die packages using interposers greater than or equal to 300mm2
  • High current products (Rated at greater than or equal to 3amps) that use smaller package designs (with die sizes less than 300mm2 ) incorporating the flip chip on lead-frame (FCOL) interconnect.

They call for the exemption to be renewed for five years, as alternatives to the current uses of lead in these applications do not meet performance standards.

Both of these exemption renewals are expected to have a dramatic impact, as they are both widely used throughout the industry. Further analysis on these exemptions will be provided when the review process is complete.

For more information on the RoHS Directive and exemptions, read our blog or contact our regulatory experts at

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