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Restriction of Hazardous Substances (RoHS) Exemption for Lead Update

The Restriction of Hazardous Substances, or RoHS as commonly abbreviated, is the European Union’s directive dealing with hazardous substance use in many industrial, commercial, and consumer applications. Among them are electronics (of many classifications) as well as piezoelectric ceramics and glass materials which contain lead(Pb).


APC International, through its colleagues at the Ultrasonics Industry Association (UIA), has been paying close attention to the rules limiting lead(Pb)-containing components used in electronic equipment and lead(Pb) use in piezoelectric ceramics for quite some time.


When it comes to specific applications and materials, the RoHS directive includes a short list of “exemptions” to the standard which allows manufacturers and end users to include limited, yet potentially hazardous substances if alternatives are not readily available or equally as effective. One exemption (exemption 7-C) concerning the use of lead(Pb) in piezoelectric ceramics presently exists allowing lead(Pb) to be used in the manufacture of PZT (lead-zirconate-titanate) type piezoelectric ceramic products.

This exemption, along with several others, are time limited and must be reviewed before they are extended into the future. For most applications, the current review deadline is July 21st, 2021. However, the deadline for application for the extension of an exception is 18 months prior to the review date for that particular exception.


A European Initiative (the Umbrella Project), which is supported by many suppliers and end users of lead(Pb) in ceramics, glass and electronic equipment in both Japanese and European organizations, submitted exemption extension applications requesting the exemption for lead(Pb) in these materials be extended through 2026. These extension applications were submitted in December 2019.


In December 2020, the Umbrella Project and others finally received a reply from the RoHS Committee at the Oeko-Institut requesting additional clarifying information to be received by the end of January 2021. This was submitted.


It is still unknown at this time if exemption 7-C will be extended, or if electronic equipment containing lead(Pb) will be able to be sold in the European market after July, 2021.


Hopefully, the commission will announce favorable results very soon as the impact of the exemption is felt across all industries including automotive, medical, defense, commercial, consumer-electronics, etc.
APC International will be continuing to receive updates on these matters, and we will pass along any additional information as soon as we can!

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