There is still much confusion over the RoHS directive in mechanical engineering companies, especially with respect to the category 8 and 9 exemptions. These were hardware devices which:
1) Generally had a long lifespan and were manufactured in small amounts.
2) Were often used in mission-critical applications where their failure would have catastrophic effects. The reliability of lead-free components and solders was unknown (five years being the minimum period for risk assessment) and so these products were made exempt.
The exemptions covered mainly the medical, military/defence, monitoring/recording and telecommunications fields. However, the exclusions were only temporary, lasting as long as it took for RoHS compliant alternatives to be quality assessed.
Mechanical engineering companies must not get complacent just because they manufacture medical or aerospace equipment on the exclusion list. This list is constantly being reviewed, with products being deleted at regular intervals, either due to re-evaluation or because the expiry date has passed. The EU recently published an updated list of the exemptions that had either expired or been removed. They included:
Lead in RIG (rare earth iron garnet) Faraday rotators of fibre optic communication systems.
DecaBDE in polymeric applications.
Lead solder in transducers of high-powered loudspeakers.
Hexavalent chromium used in corrosion protection and Electromagnetic Interference Shielding of certain IT and telecommunications equipment.
Cadmium optocoupler photoresistors used in professional audio equipment.
Mercury as a cathode sputtering inhibitor in DC plasma displays.
It is essential your obsolescence management is up to scratch in order to keep ahead of RoHS and REACH compliance issues. Luckily, we at Enventure technologies have obsolescence management tools and master data management services to keep you totally RoHS compliant.
