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CLOSED
Stakeholder consultation on
Adaptation to scientific and technical
progress
under Directive
2002/95/EC
of the European Parliament and
of the Council on the restriction of
the use of certain hazardous
substances in electrical and electronic equipment
for the purpose of a possible
amendment of the annex
|
Note: with this consultation stakeholders are not requested
to submit additional requests for exemption.
Stakeholders are requested to comment on the exemptions listed
in this consultation document and to respond to the four questions
with as much detail as possible.
1. Introduction
Article 4(1) of Directive 2002/95/EC on the restriction of the
use of certain hazardous substances in electrical and electronic
equipment [1] provides ‘that from 1 July 2006,
new electrical and electronic equipment put on the market does
not contain lead, mercury, cadmium, hexavalent chromium, PBB or
PBDE.’ The annex to the Directive lists a number of applications
of lead, mercury, cadmium and hexavalent chromium, which are exempted
from the requirements of Article 4(1).
According to Article 5 (2) of Directive 2002/95/EC the Commission
is required to consult the relevant stakeholders before amending
the annex. The results of this consultation will be forwarded
to the Technical Adaptation Committee of the Directive 2002/95/EC
and the Commission services will provide an account of the information
received. Although the Commission will analyse the results of
this stakeholder consultation carefully, please note that as with
all stakeholder consultations, this action is only one part
of the decision making process.
Neither the fact that a stakeholder consultation is being
launched, nor the results of this stakeholder consultation should
be interpreted as a political or legal signal that the Commission
intends to take a given action.
2. Proposal for additional exemptions
Article 5(1)(b) of Directive 2002/95/EC provides that materials
and components can be exempted from the substance restrictions
contained in Article 4(1) if their elimination or substitution
via design changes or materials and components which do not require
any of the materials or substances referred to therein is technically
or scientifically impracticable, or where the negative environmental,
health and/or consumer safety impacts caused by substitution outweigh
the environmental, health and/or consumer safety benefits thereof.
On the basis of this provision the Commission has received from
industry additional requests for applications to be exempted from
the requirements of the RoHS Directive.
It should be noted that since the wording for some of the exemptions
is not self explanatory, some exemption requests may overlap with
exemption requests covered by previous consultations. The Commission
services have published the requests as worded by the submitters.
The titles for the exemptions as submitted by industry and the
request for exemptions, with the substantiated evidence (available
by clicking on the title), are:
-
Lead
used for shielding of x-radiation emissions for CRT;
-
Lead
as soldering alloy in high performance communication electronic
board and hexavalent chromium (Cr-VI);
-
GemCore
410 EMV;
-
SAVBIT solder;
-
Sn-Pb soldering used in Ground-based Aeronautical Communication
Equipment Manufacturing;
-
Transducers used in professional loudspeaker systems, using
tin-lead solder;
-
Tin-lead
solder in the manufacture of professional audio equipment;
-
Inventory
of special ICS having tin-lead solder on/in leads/balls, used
in specialist/professional equipment;
-
Crystal Stones within the battery operated watch;
-
EEE used for the broadcast and homeland security sector;
-
AM186ES-V40
containing lead in used in the leads over plating and AM79C961AKC
containing lead in used in the leads over plating;
-
Cadmium sulphide or cadmium selenide in polymer based thin
film transistor;
-
Lead used in the soldering for surface finishing at the electric
pole terminal on the electronic parts;
-
Cadmium contained in the cadmium oxide of a thick film ceramic
substrate;
-
All electronics assemblies using lead in solder;
-
Lead in electric overblankets for Hot Spot detection;
-
MPC10 used in automatic vending machines to achieve the payment
by card;
-
Hexavalent
Chrome Cr-VI when used as a passivate;
-
Lead contained in circuit boards, obsolete and non-compliant
Intel 80c188/86 EA\XL microprocessors, Analog Devices ADMC300
DSP, and NEC uPD7101 DART and hexavalent chromium;
-
Component used in the manufacture of electric blankets and
heating pads.
-
Request to delete exemption for "Lead as impurity in
RIG (rare earth iron garnet) Faraday rotators used for fibre
optic communications systems."
-
Lead in Trimmer Potentiometer elements.
-
Cadmium in opto-electronic components.
4. Consultation of interested parties
For the consideration of the items listed above based on Article
5(1) (b), the Commission services would like to consult interested
parties.
In particular, stakeholders are requested to provide, for
each entry, information on: the current existence of feasible
substitutes in an industrial and/or commercial scale; any restrictions
that apply to such substitutes; the costs and benefits and advantages
and disadvantages of such a substitutes; provide a precise wording
for each exemption. Stakeholders are requested to support, as
far as possible, their contribution with technical and scientific
evidence.
It shall be noted that submissions containing generic comments,
statements, position papers and additional request for exemptions
will not be taken into account.
1. Lead used for shielding of x-radiation emissions for CRT.
- Do feasible substitutes currently exist in an industrial and/or
commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages
of such substitutes?
- Are there any negative environmental, health and/or consumer
safety impacts caused by substitution which are likely to outweigh
the environmental, health and/or consumer benefits thereof?
- Please indicate a precise wording for this exemption.
2. Lead as soldering alloy in high performance communication
electronic board and hexavalent chromium (Cr-VI).
- Do feasible substitutes currently exist in an industrial and/or
commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages
of such substitutes?
- Are there any negative environmental, health and/or consumer
safety impacts caused by substitution which are likely to outweigh
the environmental, health and/or consumer benefits thereof?
- Please indicate a precise wording for this exemption.
3. GemCore 410 EMV.
- Do feasible substitutes currently exist in an industrial and/or
commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages
of such substitutes?
- Are there any negative environmental, health and/or consumer
safety impacts caused by substitution which are likely to outweigh
the environmental, health and/or consumer benefits thereof?
- Please indicate a precise wording for this exemption.
4. SAVBIT solder.
- Do feasible substitutes currently exist in an industrial and/or
commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages
of such substitutes?
- Are there any negative environmental, health and/or consumer
safety impacts caused by substitution which are likely to outweigh
the environmental, health and/or consumer benefits thereof?
- Please indicate a precise wording for this exemption.
5. Sn-Pb soldering used in Ground-based Aeronautical Communication
Equipment Manufacturing.
- Do feasible substitutes currently exist in an industrial and/or
commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages
of such substitutes?
- Are there any negative environmental, health and/or consumer
safety impacts caused by substitution which are likely to outweigh
the environmental, health and/or consumer benefits thereof?
- Please indicate a precise wording for this exemption.
6. Transducers used in professional loudspeaker systems, using
tin-lead solder.
- Do feasible substitutes currently exist in an industrial and/or
commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages
of such substitutes?
- Are there any negative environmental, health and/or consumer
safety impacts caused by substitution which are likely to outweigh
the environmental, health and/or consumer benefits thereof?
- Please indicate a precise wording for this exemption.
7. Tin-lead solder in the manufacture of professional audio
equipment.
- Do feasible substitutes currently exist in an industrial and/or
commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages
of such substitutes?
- Are there any negative environmental, health and/or consumer
safety impacts caused by substitution which are likely to outweigh
the environmental, health and/or consumer benefits thereof?
- Please indicate a precise wording for this exemption.
8. Inventory of special ICS having tin-lead solder on/in leads/balls,
used in specialist/professional equipment.
- Do feasible substitutes currently exist in an industrial and/or
commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages
of such substitutes?
- Are there any negative environmental, health and/or consumer
safety impacts caused by substitution which are likely to outweigh
the environmental, health and/or consumer benefits thereof?
- Please indicate a precise wording for this exemption.
9. Crystal Stones within the battery operated watch.
- Do feasible substitutes currently exist in an industrial and/or
commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages
of such substitutes?
- Are there any negative environmental, health and/or consumer
safety impacts caused by substitution which are likely to outweigh
the environmental, health and/or consumer benefits thereof?
- Please indicate a precise wording for this exemption.
10. EEE used for the broadcast and homeland security sector.
- Do feasible substitutes currently exist in an industrial and/or
commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages
of such substitutes?
- Are there any negative environmental, health and/or consumer
safety impacts caused by substitution which are likely to outweigh
the environmental, health and/or consumer benefits thereof?
- Please indicate a precise wording for this exemption.
11. AM186ES-V40 containing lead in used in the leads over
plating and AM79C961AKC containing lead in used in the leads over
plating.
- Do feasible substitutes currently exist in an industrial and/or
commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages
of such substitutes?
- Are there any negative environmental, health and/or consumer
safety impacts caused by substitution which are likely to outweigh
the environmental, health and/or consumer benefits thereof?
- Please indicate a precise wording for this exemption.
12. Cadmium sulphide or cadmium selenide in polymer based
thin film transistor.
- Do feasible substitutes currently exist in an industrial and/or
commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages
of such substitutes?
- Are there any negative environmental, health and/or consumer
safety impacts caused by substitution which are likely to outweigh
the environmental, health and/or consumer benefits thereof?
- Please indicate a precise wording for this exemption.
13. Lead used in the soldering for surface finishing at the
electric pole terminal on the electronic parts.
- Do feasible substitutes currently exist in an industrial and/or
commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages
of such substitutes?
- Are there any negative environmental, health and/or consumer
safety impacts caused by substitution which are likely to outweigh
the environmental, health and/or consumer benefits thereof?
- Please indicate a precise wording for this exemption.
14. Cadmium contained in the cadmium oxide of a thick film
ceramic substrate.
- Do feasible substitutes currently exist in an industrial and/or
commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages
of such substitutes?
- Are there any negative environmental, health and/or consumer
safety impacts caused by substitution which are likely to outweigh
the environmental, health and/or consumer benefits thereof?
- Please indicate a precise wording for this exemption.
15. All electronics assemblies using lead in solder.
- Do feasible substitutes currently exist in an industrial and/or
commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages
of such substitutes?
- Are there any negative environmental, health and/or consumer
safety impacts caused by substitution which are likely to outweigh
the environmental, health and/or consumer benefits thereof?
- Please indicate a precise wording for this exemption.
16. Lead in electric overblankets for Hot Spot detection.
- Do feasible substitutes currently exist in an industrial and/or
commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages
of such substitutes?
- Are there any negative environmental, health and/or consumer
safety impacts caused by substitution which are likely to outweigh
the environmental, health and/or consumer benefits thereof?
- Please indicate a precise wording for this exemption.
17. MPC10 used in automatic vending machines to achieve the
payment by card.
- Do feasible substitutes currently exist in an industrial and/or
commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages
of such substitutes?
- Are there any negative environmental, health and/or consumer
safety impacts caused by substitution which are likely to outweigh
the environmental, health and/or consumer benefits thereof?
- Please indicate a precise wording for this exemption.
18. Hexavalent Chrome Cr-VI when used as a passivate.
- Do feasible substitutes currently exist in an industrial and/or
commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages
of such substitutes?
- Are there any negative environmental, health and/or consumer
safety impacts caused by substitution which are likely to outweigh
the environmental, health and/or consumer benefits thereof?
- Please indicate a precise wording for this exemption.
19. Lead contained in circuit boards, obsolete and non-compliant
Intel 80c188/86 EA\XL microprocessors, Analog Devices ADMC300
DSP, and NEC uPD7101 DART and hexavalent chromium.
- Do feasible substitutes currently exist in an industrial and/or
commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages
of such substitutes?
- Are there any negative environmental, health and/or consumer
safety impacts caused by substitution which are likely to outweigh
the environmental, health and/or consumer benefits thereof?
- Please indicate a precise wording for this exemption.
20. Component used in the manufacture of electric blankets
and heating pads.
- Do feasible substitutes currently exist in an industrial and/or
commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages
of such substitutes?
- Are there any negative environmental, health and/or consumer
safety impacts caused by substitution which are likely to outweigh
the environmental, health and/or consumer benefits thereof?
- Please indicate a precise wording for this exemption.
21. Request to delete exemption for "Lead as impurity
in RIG (rare earth iron garnet) Faraday rotators used for fibre
optic communications systems".
- Do feasible substitutes currently exist in an industrial and/or
commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages
of such substitutes?
- Are there any negative environmental, health and/or consumer
safety impacts caused by substitution which are likely to outweigh
the environmental, health and/or consumer benefits thereof?
- Please indicate a precise wording for this exemption.
22. Lead in Trimmer Potentiometer elements.
- Do feasible substitutes currently exist in an industrial and/or
commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages
of such substitutes?
- Are there any negative environmental, health and/or consumer
safety impacts caused by substitution which are likely to outweigh
the environmental, health and/or consumer benefits thereof?
- Please indicate a precise wording for this exemption.
23. Cadmium in opto-electronic components.
- Do feasible substitutes currently exist in an industrial and/or
commercial scale?
- Do any restrictions apply to such substitutes?
- What are the costs and benefits and advantages and disadvantages
of such substitutes?
- Are there any negative environmental, health and/or consumer
safety impacts caused by substitution which are likely to outweigh
the environmental, health and/or consumer benefits thereof?
- Please indicate a precise wording for this exemption.
Interested parties are invited to send their comments by 10
January 2007 at the latest by e-mail to ENV-RoHS@ec.europa.eu or by post to:
European Commission
DG Environnent, Unit G.4 – Consultation Directive 2002/95/EC
B-1049, Brussels, Belgium.
***
Responses submitted electronically will be posted on this web
site as they are received, unless respondents specifically request
that their contribution should not be publicised. In the latter
case, responses should be clearly and visibly marked with the
words "Not for publication”.
***
[1] OJ L 37, 13.2.2003, p. 19