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On February 25, 2022, Oeko Institute published the final evaluation report of RoHS 2.0 directive exemption pack 24 on its official website, which gave relevant suggestions on whether to extend Clauses 5 (b), 18 (b), 18 (b) - I, 24, 29, 32 and 34 in Annex III and 34 in annex IV. Pack 24 involves exemption clauses for lead content. For example, Annex III, 24 "lead contained in solder of through-hole disk and planar array ceramic multilayer capacitors" has been given an "18-month transition period" in this evaluation report, and Clause 24 (a) has been added to refine the scope of exemption.
The EU will make a final decision on whether to postpone or not with reference to this assessment report. Therefore, the publication of the final assessment report has certain guiding significance for enterprises. Enterprises that use relevant exemption provisions need to pay attention to the suggestions on relevant exemptions given in the assessment report.
Please refer to the following table for the recommendations and validity period of the report:
Exemptions Clauses | Exemptions Contents | Suggestions | Validity & Scope |
AnnexⅢ,5(b) | Lead in glass of fluorescent tubes not exceeding 0.2% by weight | Lead (not intentionally added) in soda lime glass used in the glass tube of fluorescent lamps, not exceeding 0.2% by weight | 21 July 2026 for category 5 |
AnnexⅢ,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 | 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(BaSi205:Pb) | 21 July 2026 for categories 5,8 and 9; 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11 |
AnnexⅢ,18(b)-Ⅰ | Lead as activator in the fluorescent powder (1% lead by weight or less) of discharge lamps containing phosphors such as BSP when used in medical phototherapy equipment | It is recommended to group exemption 18(b)-ⅠAnnex Ⅲ and exemption 34 Annex Ⅳ under a new item(18(b)-Ⅱ) in Annex Ⅲ. The proposed wording for the new item has no implications on the scope of existing exemptions 18(b)-Ⅰ and Ex.34 | For the new item 18(b)-Ⅱ |
Annex Ⅳ 34 | Lead as activator in the fluorescent powder of discharge lamps when used for extracorporeal photopheresis lamps containing BSP (BaSi205:Pb) phosphors | ||
Annex Ⅲ 24 | Lead in solders for the soldering to machine through hole discoidal and planar array ceramic multilayer capacitors. | Lead in solders for the soldering to machine through hole discoidal and planar array ceramic multilayer capacitors | 18-month transition period |
New item:24(a): | 21 July 2026 for categories 1-11 | ||
Annex Ⅲ 29 | Lead bound in crystal glass as defined in AnnexⅠ(Categories 1,2,3 and 4) of Council Directive 69/494/EEC | Lead bound in crystal glass as defined in AnnexⅠ(Categories 1,2,3 and 4) of Council Directive 69/494/EEC | 21 July 2026 for categories3,4,5 and 11; |
Annex Ⅲ 32 | Lead oxide in seal frit used for making window assemblies for Argon and Krypton laser tubes | Lead oxide in glass frit used as a sealing material for making window assemblies for argon and/or Krypton laser tubes | 21 July 2024 for category 11; |
Annex Ⅲ 34 | Lead in cermet-based trimmer potentiometer elements | Lead in cermet-based trimmer potentiometer elements | 21 July 2024 for all categories |
EQO Advice
The renewal of RoHS exemption clauses has a great impact on electronic and electrical related industries. In particular, the extension of some exemption clauses frequently used by enterprises may directly affect the production process and business activities of enterprises. It is suggested that manufacturers of electronic and electrical products continue to pay attention to the update progress of RoHS exemption clauses, timely obtain the latest information related to RoHS exemption, and carry out supply chain investigation, so as to respond in time when the exemption is updated.