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Waste

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.

***

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