| 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 only 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 limited 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:
1. Cadmium
and cadmium oxide in thick film pastes used on beryllium oxide
substrates until January 1, 2008;
2. Gaskets
of butyl rubber material vulcanised with chinondioxim and lead
tetraoxide, for use in Aluminium Electrolytic Capacitors;
3. Sharp
LQ104X2LX11 (formerly Fujitsu FLC26XGC6R-01);
4. Quartz
Crystal Resonator and in Fine Pitch Electronics Systems used in
the Swiss Watch Industry;
5. Cadmium
in opto- electronic components;
6. Transducers
used in professional loudspeaker systems, using tin-lead solder;
7. Tin-lead
solder in the manufacture of professional audio equipment;
8. Components
used in the manufacture of the Hog1000, Hog500, Event416, Event408,
ESP2-24 and ESP2-48 lighting control consoles;
9. Specific
modular units, including tin-lead solder, being used in special
professional equipment;
10. Inventory
of special ICS having tin-lead solder on/in leads/balls, used
in specialist/professional equipment;
11. Cadmium
Mercury Telluride;
12. Lead
contained in Babbit lined bearings;
13. Cadmium
alloys as electrical/mechanical solder joints to electrical conductors
located directly on the voice coil in transducers used in high-powered
loudspeakers;
14.
Thermal cutoff with a fusible element that contains lead (and
possibly cadmium, mercury and hexavalent chromium) for applications
where normal operating temperature exceeds 140 C and reliable,
predictable, operation for a minimum of 30,000 hours is required;
15. Mercury
free flat panel lamp;
16. Electronic
equipment where the reliability, durability and longevity of the
equipment is paramount;
17. Semi
Red Brass C84400, 81-3-7-9 or a similar Brass material. Used on
radio frequency line sections;
18. Lead
is used as an alloy to the copper in 6 to 8 % by weight. Needed
for casting and machinability characteristics;
19. Lead
in solders for electronic equipments used for the monitoring,
the protection and the safety of people in healthcare, telecare
and emergency calls domains in professional and private sectors;
20. FPGA
devices manufactured by Xilinx (XC5202-6VQ100C, XC4003E-3VQ100C
and XC4013E-3PQ240C) containing lead solder (Pb) used in the plating
of the device terminations;
21. Lead
oxide in seal frit used for making window assemblies for argon
and krypton laser tubes;
22. Smart
card readers (product: GemSelf700-MS2, GCR700-3ZS, Vodafone D2
, GCR760 and GemSelf750 SV);
23. Use
of mercury in Babcock’s DC plasma displays and use of Lead Oxide
(PbO) in Babcock’s DC plasma displays frit seal.
4. Consultation of interested parties
In preparation of the decision 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.
1. Cadmium and cadmium oxide in thick film pastes used on
beryllium oxide substrates until January 1, 2008.
- 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. Gaskets of butyl rubber material vulcanised with chinondioxim
and lead tetraoxide, for use in Aluminium Electrolytic Capacitors.
- 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. Sharp LQ104X2LX11 (formerly Fujitsu FLC26XGC6R-01).
- 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. Quartz Crystal Resonator and in Fine Pitch Electronics
Systems used in the Swiss Watch Industry.
- 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. 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.
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. Components used in the manufacture of the Hog1000, Hog500,
Event416, Event408, ESP2-24 and ESP2-48 lighting control consoles.
- 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. Specific modular units, including tin-lead solder, being
used in special 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.
10. 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.
11. Cadmium Mercury Telluride.
- 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. Lead contained in Babbit lined bearings.
- 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. Cadmium alloys as electrical/mechanical solder joints
to electrical conductors located directly on the voice coil in
transducers used in high-powered loudspeakers.
- 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. Thermal cutoff with a fusible element that contains lead
(and possibly cadmium, mercury and hexavalent chromium) for applications
where normal operating temperature exceeds 140 C and reliable,
predictable, operation for a minimum of 30,000 hours is required.
- 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. Mercury free flat panel lamp.
- 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. Electronic equipment where the reliability, durability
and longevity of the equipment is paramount.
- 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. Semi Red Brass C84400, 81-3-7-9 or a similar Brass material.
Used on radio frequency line sections.
- 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. Lead is used as an alloy to the copper in 6 to 8 % by
weight. Needed for casting and machinability characteristics.
- 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 in solders for electronic equipments used for the
monitoring, the protection and the safety of people in healthcare,
telecare and emergency calls domains in professional and private
sectors.
- 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. FPGA devices manufactured by Xilinx (XC5202-6VQ100C, XC4003E-3VQ100C
and XC4013E-3PQ240C) containing lead solder (Pb) used in the plating
of the device terminations.
- 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. Lead oxide in seal frit used for making window assemblies
for argon and krypton laser tubes.
- 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. Smart card readers (product: GemSelf700-MS2, GCR700-3ZS,
Vodafone D2 , GCR760 and GemSelf750 SV).
- 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. Use of mercury in Babcock’s DC plasma displays and use
of Lead Oxide (PbO) in Babcock’s DC plasma displays frit seal.
- 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 15
May 2006 at the latest by e-mail to ENV-RoHS@ec.europa.eu
or by post to:
European Commission
DG Environnent, Unit G4 – Consultation Directive
2002/95/EC
B-1049, Brussels, Belgium.
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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”.
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