RoHS Directive 2014/5/EU Leaded Solder Exemption

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BubbaDog56

#1
This exemption directive is included as one of Directives 2014/1/EU - 2014/8/EU that were published on October 18th of 2013. It regards a leaded solder exemption for components, connections, cables and assemblies that are designed to operate at below -20 degrees C.

The other 7 directives all specifically mention various medical device applications regarding the exemptions, however this one does not. This would indicate that the exemption is applicable to any type of device, and is not medical specific. We manufacture a variety of industrial sensor products, cables, connectors and electronics that have published specifications for operation below -20C, it seems that this exemption would apply to these products.

Has anyone else looked at/taken this as a valid exemption for non-medical products?
 
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somashekar

Staff member
Super Moderator
#2
The Annex IV in the 2011/65/EU concerns to Applications exempted from the restriction in Article 4(1) specific to medical devices and monitoring and control instruments.
Is your item a part of the monitoring and control instruments...

In Annex IV to Directive 2011/65/EU the following point 26 is added:

‘26. Lead in—solders on printed circuit boards,—termination coatings of electrical and electronic components and coatings of printed circuit boards,solders for connecting wires and cables,—solders connecting transducers and sensors,that are used durably at a temperature below – 20 °C under normal operating and storage conditions.Expires on 30 June 2021.’
 
B

BubbaDog56

#3
Thanks for pointing that out, I missed the fact that it was applicable only to Annex IV. However, we do consider our sensors to fall under monitoring equipment. One of the major issues with the Directive overall is there is no good guidance regarding where specialized industrial products fall as far as applicable categories, and monitoring and control is a very broad description. So you're forced to make some assumptions and hope that you're right if ever challenged.
 
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