RoHS Components with Lead Exemptions (Capacitors on a PCB)

J

Janselm

#1
Probably a dumb question but...

If my companies products are to be 100% RoHS compliant with no exemptions, do I have to make sure I do not buy components that say they are RoHS compliant but have a lead exemption?

For instance: Our product claims lead-free but one of the capacitors on a PCB in the product is RoHS compliant with a lead exemption. Would I have to get rid of this component or can I keep it? My first thought is get rid of it because that would put lead in my product and we don't have an exemption for lead. But my second thought is I can keep it because the component is still RoHS compliant.

Does anyone know the answer to this?
 
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Jaydub

Involved In Discussions
#2
RoHS compliant does not necessarily mean lead-free. Certain exemptions are detailed in Annex III of the directive that allow lead concentrations above .1%.

If the part in question is RoHS compliant, with a valid exemption, it should be fine to use in a RoHS compliant product. You might want to be careful about claiming it's lead-free however.
 
J

JackPack

#3
I say your product is RoHS Compliant, but cannot claim "RoHS Compliant with no exemptions".

The easy fix is just take out the "no exemptions" from where you are making the claim.
 
J

Janselm

#4
I say your product is RoHS Compliant, but cannot claim "RoHS Compliant with no exemptions".

The easy fix is just take out the "no exemptions" from where you are making the claim.
We do not claim "no exemptions." We claim "CE" and since RoHS is a necessity for electronic equipment to claim "CE" we also only say "RoHS Compliant". However, by claiming RoHS compliant it is assumed that you do not have any exemptions. When I say we claim lead-free what I mean is we claim RoHS and our lead content is under .1%.

Exemptions are NOT easy to obtain and we don't really want to go for an exemption if we don't have to. You are not allowed to just say you claim the exemption, you have to actually apply for it and be approved. It takes a lot of research and paperwork to show that you need the exemption and there are no alternatives.

Without an exemption I don't think we can use parts even if they are RoHS compliant with a lead exemption. This is because there may actually be lead in the component and therefore lead in my product that might push the lead content above .1%. If this happens then I would think the product is not RoHS compliant.

Maybe I'm over-thinking this too much...
 
J

JackPack

#5
We do not claim "no exemptions." We claim "CE" and since RoHS is a necessity for electronic equipment to claim "CE" we also only say "RoHS Compliant". However, by claiming RoHS compliant it is assumed that you do not have any exemptions. When I say we claim lead-free what I mean is we claim RoHS and our lead content is under .1%.

Exemptions are NOT easy to obtain and we don't really want to go for an exemption if we don't have to. You are not allowed to just say you claim the exemption, you have to actually apply for it and be approved. It takes a lot of research and paperwork to show that you need the exemption and there are no alternatives.

Without an exemption I don't think we can use parts even if they are RoHS compliant with a lead exemption. This is because there may actually be lead in the component and therefore lead in my product that might push the lead content above .1%. If this happens then I would think the product is not RoHS compliant.

Maybe I'm over-thinking this too much...
Just want to discuss this alittle bit more, for my benefits too :D

1. When RoHS compliant is claimed, it is not assumed that no exemptions are applied. If the exemptions applied are not expired and are still valid, your product is still CE compliant (RoHS wise)

2. Not sure if the concentration limits are being misunderstood, but the .1% limit is on the homogeneous level, not at the product level. Assuming the pcb board is the final product, and it contains the capacitor with > .1% lead; without applying for exemptions, the final product (pcb board) is not RoHS compliant either.

3. Exemptions are not "obtained", they are listed in the Annex III of the Directive 2011/65/EU. It is up to you to see if the exemptions can be applied to your products (or component in your example).

4. I re-read your original post. If your final goal is to make all your products RoHS complaint without exemptions, then I guess you can't use that capacitor.

Hope I am helping :cool:
 
J

Janselm

#6
Just want to discuss this alittle bit more, for my benefits too :D

1. When RoHS compliant is claimed, it is not assumed that no exemptions are applied. If the exemptions applied are not expired and are still valid, your product is still CE compliant (RoHS wise)
If someone states their product is RoHS compliant I am going to assume it meets all the necessary levels of restricted materials. How would the end user of a component know to trust if a component has lead in it or not for their own RoHS compliance? Not every component has a material data sheet.

2. Not sure if the concentration limits are being misunderstood, but the .1% limit is on the homogeneous level, not at the product level. Assuming the pcb board is the final product, and it contains the capacitor with > .1% lead; without applying for exemptions, the final product (pcb board) is not RoHS compliant either.
This I did not understand. Thank you for clarifying.

3. Exemptions are not "obtained", they are listed in the Annex III of the Directive 2011/65/EU. It is up to you to see if the exemptions can be applied to your products (or component in your example).
You have to apply and be approved for exemptions...

From Article 5:
For the exemptions listed in Annex III as at 21 July 2011, the
maximum validity period, which may be renewed, shall, for
categories 1 to 7 and 10 of Annex I, be 5 years from
21 July 2011 and, for categories 8 and 9 of Annex I, 7 years
from the relevant dates laid down in Article 4(3), unless a
shorter period is specified.


An application for granting, renewing or revoking an exemption shall be made to the Commission in accordance
with Annex V

ANNEX V
Applications for granting, renewing and revoking exemptions as referred to in Article 5
Applications for exemptions, renewal of exemptions or,
mutatis mutandis
, for revoking an exemption may be submitted by
a manufacturer, the authorised representative of a manufacturer, or any economic operator in the supply chain and shall
include at least the following:
(a) the name, address and contact details of the applicant;
(b) information on the material or component and the specific uses of the substance in the material and component for
which an exemption, or its revocation, is requested and its particular characteristics;
(c) verifiable and referenced justification for an exemption, or its revocation, in line with the conditions established in
Article 5;
(d) an analysis of possible alternative substances, materials or designs on a life-cycle basis, including, when available,
information about independent research, peer-review studies and development activities by the applicant and an
analysis of the availability of such alternatives;
(e) information on the possible preparation for reuse or recycling of materials from waste EEE, and on the provisions
relating to the appropriate treatment of waste according to Annex II to Directive 2002/96/EC;
(f) other relevant information;
(g) the proposed actions to develop, request the development and/or to apply possible alternatives including a timetable
for such actions by the applicant;
(h) where appropriate, an indication of the information which should be regarded as proprietary accompanied by
verifiable justification;
(i) when applying for an exemption, proposal for a precise and clear wording for the exemption;
(j) a summary of the application

4. I re-read your original post. If your final goal is to make all your products RoHS complaint without exemptions, then I guess you can't use that capacitor.
Hope I am helping :cool:[/QUOTE]

This is what I was thinking as well.
 
J

Janselm

#7
We have an exemption for lead but it expires in 2016. This is why we currently have components with exemptions. We wanted to get away from exemptions as it seems to be preferable in the European market especially when the bulk of our customers are government and we don't really want to go through the process of reapplying for the exemption if we don't have to. We are removing lead solder from our products but I did not know if we needed to remove components with lead in them as well even if they were claiming RoHS but with a lead exemption.
 
J

JackPack

#8
If someone states their product is RoHS compliant I am going to assume it meets all the necessary levels of restricted materials. How would the end user of a component know to trust if a component has lead in it or not for their own RoHS compliance? Not every component has a material data sheet.
Different practices vary from businesses to businesses, but from what I see usually a supplier certificate of conformity or declaration of conformity is requested before purchasing the part that will state the part's compliance, exemptions applied, etc...


You have to apply and be approved for exemptions...

From Article 5:
For the exemptions listed in Annex III as at 21 July 2011, the
maximum validity period, which may be renewed, shall, for
categories 1 to 7 and 10 of Annex I, be 5 years from
21 July 2011 and, for categories 8 and 9 of Annex I, 7 years
from the relevant dates laid down in Article 4(3), unless a
shorter period is specified...
Sorry didn't know you guys actually applied for an exemption to your technology. Pretty interesting. What exemption is that if you don't mind me asking? Was it added to the exemption table in the Annex III?

Thanks for the response:thanx:
 
J

Janselm

#9
7(b)
Lead in solders for servers, storage and storage array
systems, network infrastructure equipment for switching,
signalling, transmission, and network management for tele
communications
 
J

Janselm

#10
Different practices vary from businesses to businesses, but from what I see usually a supplier certificate of conformity or declaration of conformity is requested before purchasing the part that will state the part's compliance, exemptions applied, etc...
This is what I was getting at. We have a few certificates of conformity that have exemptions. All I really want to know is if we can still claim RoHS compliant even if we use these parts. I'm sorry this has been racking my brain and I'm probably over-complicating things.
 
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