EU RoHS

March 7, 2019 | Written by GreenSoft Technology, Inc.

European Commission Issues 10 Updates to EU RoHS Exemptions

Updated EU RoHS Exemptions List Available to Download

eu-rohsIn February, the European Commission issued 10 updates to exemptions under the EU RoHS-2 regulation.

The exemption updates were published in the Official Journal of the European Union on 5 February 2019. They are summarized at the bottom of this post.

The last prior batch of EU RoHS exemption updates was in May 2018.

GreenSoft maintains a compiled list of the EU RoHS Exemptions in order to perform EU RoHS Data Services for our customers and to keep our GreenData Manager software up-to-date. Our compiled list has now been updated to include the recent changes by the European Commission.

You can download the updated EU RoHS Exemptions List here.

GreenSoft Keeps Track of RoHS-2 Exemptions So You Don’t Have To

Updates and exemptions to regulations occur regularly. With the status and timing of exemption extensions unknown, compliance can be a continually moving target.

Affected companies using parts or materials that utilize expiring exemptions should immediately begin finding replacements and phasing out the use of those parts or materials.

GreenSoft can help with this process, including the sourcing of replacement parts. We can help you collect the substance data on your parts and format the data to meet the due diligence and documentation requirements of RoHS-2 and EN 50581. Learn more about our RoHS-2 Data Services or contact us today to get started.

Summary of February 2019 EU RoHS Exemption Updates:

Exemption Description Updates Link
Annex III, entry 7(c)-II Lead in dielectric ceramic in capacitors for a rated voltage of 125 V AC or 250 V DC or higher Does not apply to applications covered by point 7(c)-I and 7(c)-IV of this Annex.
Expires on:
— 21 July 2021 for categories 1-7 and 10;
— 21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments;
— 21 July 2023 for category 8 in vitro diagnostic medical devices;
— 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.
(EU) 2019/169
Annex III, entry 7(c)-IV Lead in PZT based dielectric ceramic materials for capacitors which are part of integrated circuits or discrete semiconductors Expires on:
— 21 July 2021 for categories 1-7 and 10;
— 21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments;
— 21 July 2023 for category 8 in vitro diagnostic medical devices;
— 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.
(EU) 2019/170
In Annex III to Directive 2011/65/EU, entry 8(b) is replaced by the following 8(b) and 8(b)-I:
Annex III to Directive 2011/65/EU, entry 8(b) Cadmium and its compounds in electrical contacts Applies to categories 8, 9 and 11 and expires on:
— 21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments;
— 21 July 2023 for category 8 in vitro diagnostic medical devices;
— 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.
(EU) 2019/171
Annex III to Directive 2011/65/EU, entry 8(b)-I Cadmium and its compounds in electrical contacts used in:
— circuit breakers,
— thermal sensing controls,
— thermal motor protectors (excluding hermetic thermal motor protectors),
— AC switches rated at:
— 6 A and more at 250 V AC and more, or
— 12 A and more at 125 V AC and more,
— DC switches rated at 20 A and more at 18 V DC and more, and
— switches for use at voltage supply frequency ≥ 200 Hz.
Applies to categories 1 to 7 and 10 and expires on 21 July 2021. (EU) 2019/171

In Annex III, entry 15 is replaced by the following 15 and 15(a):

Annex III, entry 15 Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit flip chip packages Applies to categories 8, 9 and 11 and expires on:
— 21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments;
— 21 July 2023 for category 8 in vitro diagnostic medical devices;
— 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.
(EU) 2019/172
Annex III, entry 15(a) Lead in solders to complete a viable electrical connection between the semiconductor die and carrier within integrated circuit flip chip packages where at least one of the following criteria applies:
— a semiconductor technology node of 90 nm or larger;
— a single die of 300 mm2 or larger in any semiconductor technology node;
— stacked die packages with die of 300 mm2 or larger, or silicon interposers of 300 mm2 or larger.
Applies to categories 1 to 7 and 10 and expires on 21 July 2021. (EU) 2019/172

In Annex III, entry 21 is replaced by the following 21, 21(a), 21(b), and 21(c):

Annex III, entry 21 Lead and cadmium in printing inks for the application of enamels on glasses, such as borosilicate and soda lime glasses Applies to categories 8, 9 and 11 and expires on:
— 21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments;
— 21 July 2023 for category 8 in vitro diagnostic medical devices;
— 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.
(EU) 2019/173
Annex III, entry 21(a) Cadmium when used in colour printed glass to provide filtering functions, used as a component in lighting applications installed in displays and control panels of EEE Applies to categories 1 to 7 and 10 except applications covered by entry 21(b) or entry 39 and expires on 21 July 2021. (EU) 2019/173
Annex III, entry 21(b) Cadmium in printing inks for the application of enamels on glasses, such as borosilicate and soda lime glasses Applies to categories 1 to 7 and 10 except applications covered by entry 21(a) or 39 and expires on 21 July 2021. (EU) 2019/173
Annex III, entry 21(c) Lead in printing inks for the application of enamels on other than borosilicate glasses Applies to categories 1 to 7 and 10 and expires on 21 July 2021. (EU) 2019/173
Annex III, entry 29 Lead bound in crystal glass as defined in Annex I (Categories 1, 2, 3 and 4) of Council Directive 69/493/EEC Expires on:
— 21 July 2021 for categories 1-7 and 10;
— 21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and ontrol instruments;
— 21 July 2023 for category 8 in vitro diagnostic medical devices;
— 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.
(EU) 2019/174
Annex III, entry 32 Lead oxide in seal frit used for making window assemblies for Argon and Krypton laser tubes Expires on:
— 21 July 2021 for categories 1-7 and 10,
— 21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments,
— 21 July 2023 for category 8 in vitro diagnostic medical devices,
— 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.
(EU) 2019/175
Annex III, entry 37 Lead in the plating layer of high voltage diodes on the basis of a zinc borate glass body Expires on:
— 21 July 2021 for categories 1-7 and 10;
— 21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments;
— 21 July 2023 for category 8 in vitro diagnostic medical devices;
— 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.
(EU) 2019/176

In Annex III, entry 18(b) is replaced by the following 18(b) and 18(b)-I:

Annex III, entry 18(b) Lead as activator in the fluorescent powder (1 % lead by weight or less) of discharge lamps when used as sun tanning lamps containing phosphors such as BSP (BaSi2O5:Pb) Expires on:
— 21 July 2021 for categories 1-7 and 10;
— 21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments;
— 21 July 2023 for category 8 in vitro diagnostic medical devices;
— 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.
(EU) 2019/177
Annex III, entry 18(b)-I Lead as activator in the fluorescent powder (1 % lead by weight or less) of discharge lamps containing phosphors such as BSP (BaSi2O5:Pb) when used in medical phototherapy equipment Applies to categories 5 and 8, excluding applications covered by entry 34 of Annex IV, and expires on 21 July 2021. (EU) 2019/177
Annex III, entry 42 Lead in bearings and bushes of diesel or gaseous fuel powered internal combustion engines applied in non-road professional use equipment:
— with engine total displacement ≥ 15 litres;
or
— with engine total displacement < 15 litres and the engine is designed to operate in applications where the time between signal to start and full load is required to be less than 10 seconds; or regular maintenance is typically performed in a harsh and dirty outdoor environment, such as mining, construction, and agriculture applications

Applies to category 11, excluding applications covered by entry 6(c) of this Annex.

Expires on 21 July 2024.

(EU) 2019/178

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EU RoHS Exemptions Timeline Update

EU RoHS Exemptions Updates: European Commission announces target adoption dates expected in third quarter 2024 for critical EU RoHS exemptions for electronics manufacturers

Conference

February 21,  2019 | Written by GreenSoft Technology, Inc.

Join us at the annual ITI & IPC Conference in June!

ITI & IPC Conference on Emerging & Critical Environmental Product Requirements

iti-ipcWe'll be visiting Boston, Chicago and Silicon Valley in June to talk about compliance solutions for regulations like EU REACH, EU RoHS, Conflict Minerals, CA Prop 65, EU MDR and many more.

Hosted by the IPC Association and the Information Technology Industry Council (ITI), this annual conference brings together industry experts to provide compliance professionals with the tools and information they need to comply with legal, regulatory, and customer requirements.

We'll be exhibiting our Data Services and GreenData Manager software solutions at the event. Join us at the events to learn more! We'll be in Boston, MA on June 3rd; Chicago, IL on June 5th; and San Jose, CA on June 7th.

Learn more or register to attend online, or visit our Events page to see our full event schedule.

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EU REACH

February 1, 2019 | Written by GreenSoft Technology, Inc.

Inspections to Check Compliance with EU REACH Coming Soon

ECHA Will Perform EU REACH Compliance Inspection Checks Throughout 2019

EU-REACH

The European Chemicals Agency (ECHA) has announced that it will be performing inspections to check compliance with the EU REACH regulation as part of its ongoing EU REACH Enforcement Project.

The project aims to ensure that obligated companies throughout the EU are registering their affected substances per EU REACH requirements. The inspection activities will continue throughout 2019. A report on the results of the inspections will be available in the fourth quarter of 2020.

Inspection checks will cover imported and manufactured substances in all tonnage bands, with main focus being on substances imported or manufactured in quantities of 1-100 tonnes per year. The inspections will also include a check of parts of the registration dossier and of other duties related to registration, for example, whether the registrant is compliant with the duty to update a registration dossier.

Inspectors in Member States will verify whether substances registered as intermediates meet the definition of intermediates and are manufactured and used under strictly controlled conditions. In addition, substances registered as monomers in polymers will be checked.

Read the ECHA news release here. Learn how GreenSoft can help you get in compliance with EU REACH here or contact us online.

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EU REACH

January 17, 2019 | Written by GreenSoft Technology, Inc.

6 New Substances Added to EU REACH SVHC Candidate List

Addition of 6 Substances Brings EU REACH SVHC Candidate List to 197 Substances

EU-REACHThe European Chemicals Agency (ECHA) has announced the addition of 6 substances to the EU REACH Substances of Very High Concern (SVHC) Candidate List. The SVHC Candidate List now contains 197 substances.

Six substances were added to the SVHC Candidate List on January 15, 2019:

# Substance name EC number CAS number Examples of use(s)
1 2,2-bis(4'-hydroxyphenyl)-4-methylpentane 401-720-1 6807-17-6 Raw material for epoxy resins, Raw materials for polycarbonate resin, Thermal paper,   Surface coatings,  Inks, Adhesives, Synthetic resin additives, Liquid crystal materials,  Photosensitizers,  recording agents, plastic materials, Electronic and optical functional materials.
2 Benzo[k]fluoranthene 205-916-6 207-08-9 Impurities in carbon black (used as coloring agent in plastics and softener in rubbers).
3 Fluoranthene 205-912-4 206-44-0 Impurities in carbon black (used as coloring agent in plastics and softener in rubbers).
4 Phenanthrene 201-581-5 85-01-8 Impurities in carbon black (used as coloring agent in plastics and softener in rubbers).
5 Pyrene 204-927-3 129-00-0 Impurities in carbon black, (used as coloring agent in plastics and softener in rubbers),
Used as a transported intermediate for the manufacture of fine chemicals.
6 1,7,7-trimethyl-3-(phenylmethylene)bicyclo[2.2.1]heptan-2-one 239-139-9 15087-24-8 UV Filters.

Companies may have legal obligations resulting from the inclusion of any substance in the SVHC Candidate List. These obligations may apply to the listed substance on its own, in mixtures, or in articles. Any supplier of articles containing an SVHC above a concentration of 0.1 % (weight by weight) has communication obligations towards customers down the supply chain and consumers.

For more information on the addition of these substances, view ECHA's news release online. The full list of 197 SVHC Candidate List substances can be viewed here. The last prior addition to the REACH SVHC Candidate List was in June 2018.

GreenSoft Can Help with EU REACH Compliance

GreenSoft helps companies manage REACH compliance with a process that includes data collection, data validation, substance calculations and report generation. We can also help with sourcing replacement parts for non-compliance parts, or recommending replacement suppliers for non-compliant or non-responsive suppliers. We're also hosting an educational webinar on EU REACH next month. Learn more about our REACH compliance services here or get started with a FREE Risk Analysis/BOM Scrub.

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Webinar

January 15, 2019 | Written by GreenSoft Technology, Inc.

Solving the EU REACH “Once an Article, Always an Article” Problem

Register Now for our Educational Webinar Explaining the EU REACH Article Definition Changes

reach-webinar

The 2015 “Once an Article, Always an Article” ruling has changed the method for calculating Substances of Very High Concern (SVHC) levels under the EU REACH regulation. The electronics manufacturing industry is still dealing with the impact.

GreenSoft is hosting an informational free-of-charge webinar that will cover everything you need to know to ensure your company is in compliance with the updated regulation and minimize your risk of exposure.

Hosted by Randy Flinders, Sr. Manager of Product Support for GreenSoft, you will learn the details of the regulation change and how to properly calculate substances under the new article definition.

Space is limited, so reserve your spot today!

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Top 20 Compliance Solution Providers

January 7, 2019 | Written by GreenSoft Technology, Inc.

GreenSoft Recognized as a Top 20 Compliance Technology Solution Provider

GreenSoft Technology Named One of the Top 20 Most Promising Compliance Technology Solution Providers by CIOReview

CIOreview-awardThe technology magazine CIOReview has named GreenSoft Technology as one of the Top 20 Most Promising Compliance Technology Solution Providers of 2018 in recognition of our data services and GreenData Manager software for EU REACH, RoHS, Conflict Minerals, CA Prop 65 and other regulation compliance.

To help companies find the right compliance technology provider, CIOReview's selection panel evaluates vendors on their capability to fulfill the need for cost-effective, flexible solutions to complex compliance challenges. The magazine compiles an annual list of the 20 solutions providers they find to be the most promising in the compliance technology industry.

GreenSoft's president, Larry Yen, was interviewed by CIOReview for the article announcing the award. Larry's interview focuses on GreenSoft's use of databases to streamline the environmental compliance process, and discusses how GreenSoft's data services and GreenData Manager software help manufacturers reduce risk and meet their always-expanding environmental compliance requirements.

CIOReview certificate

“Our green compliance solution enables companies to demonstrate compliance with global regulations while still focusing on their own core competencies as a company,” says Larry in the article.

Read the article online or check out a digital version of the December 2018 magazine edition featuring the full Top 20 list of vendors.

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Webinar

November 15, 2018 | Written by GreenSoft Technology, Inc.

View our EU Medical Devices Regulation (EU MDR) Educational Webinar

Now Available to View On-Demand: EU MDR Webinar

eu-mdrOn November 14, we hosted a webinar on the new EU Medical Devices Regulation (EU MDR).

Hosted by Randy Flinders, this educational presentation covered:

  • An overview of the EU Medical Devices Regulation (EU MDR)
  • Your responsibilities and requirements as a medical device product or parts manufacturer
  • How to ensure you’re complying with the updated version of the regulation (formerly EU Medical Device Directive)

A recording of the webinar is now available for you to view anytime online, alongside our other webinars on topics such as EU REACH or Green Compliance 101.

We will be back with more educational webinars next year!

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California Proposition 65

November 12, 2018 | Written by GreenSoft Technology, Inc.

Nickel Soluble Compounds Added to CA Prop 65 Chemical List

Nickle Soluble Compounds Added to List of Chemicals Known to the State of California to Cause Reproductive Toxicity

prop-65

Effective October 26, 2018, the Office of Environmental Health Hazard Assessment (OEHHA) is adding nickel soluble compounds to the list of chemicals known to the state of California to cause reproductive toxicity under the Safe Drinking Water and Toxic Enforcement Act of 1986 (CA Proposition 65).

The state's Developmental and Reproductive Toxicant Identification Committee (DARTIC) determined that soluble nickel compounds were shown to cause reproductive toxicity for developmental and male reproductive endpoints. This inclusion of soluble nickel compounds adds to the long list of nickel and nickel derivatives regulated under the CA Proposition 65 substances list.

Soluble nickel compounds are mostly used as intermediates in plating and other processes.  Nickel sulphate, nickel chloride, and nickel hydroxycarbonate are frequently used in electroplating. Nickel sulphate can also be used in the manufacture of nickel-based batteries. Nickel dinitrate can be used to make products used in the pretreatment of metals prior to painting and prior to cold-forming processes.

View the full list of substances restricted under CA Proposition 65 online. The last prior addition to the CA Proposition 65 substances list was in May 2018. There was also a change to the CA Proposition 65 warning label requirements for affected companies in August 2018.

Get Help with CA Proposition 65 Compliance from GreenSoft

GreenSoft provides data services for CA Proposition 65 and our GreenData Manager software includes CA Proposition 65 as one of the regulations built into the software. Contact us to learn more about how we can help your company comply with CA Proposition 65.

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Compliance Data Services & Software

November 8, 2018 | Written by GreenSoft Technology, Inc.

GreenSoft Compliance Solution Video

See how GreenSoft helps with EU REACH, EU RoHS, Conflict Minerals, CA Prop 65 and other regulation compliance

GreenSoft has created a short new video summarizing our compliance solution for environmental regulations like EU REACH, EU RoHS, Conflict Minerals, CA Prop 65 and others.

Our Data Services process involves matching your parts list with our Component Database to see how many parts we have already collected data for and will be able to instantly deliver to you.

Then we match the remaining parts with our Suppliers Database in which suppliers are ranked by how fast they can deliver data at our request so that we can provide an accurate estimate of how long your collection project will take.

Once our Data Collection team collects the data from your suppliers on your behalf, we validate the data for accuracy and completion, and input it into our GreenData Manager software for reporting.

If suppliers are unable to provide the requested data, we use our Materials Database to analyze the remaining parts and generate the needed compliance statements.

Our method ensures that 100% of your parts will be covered using high-quality data, and results in the creation of a unique Substance Database for your company which you can use to validate parts for other regulations in the future.

View the video to learn more or contact GreenSoft to receive a free risk analysis!

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IEEE Technical Organization

October 30, 2018 | Written by GreenSoft Technology, Inc.

GreenSoft’s Senior Product Support Manager Named Senior Member of the IEEE

Congratulations to GreenSoft’s Randy Flinders for being named a Senior Member of the IEEE

Randy-IEEE
We are pleased to announce that Randy Flinders, Senior Manager of Product Support for GreenSoft, has been recognized as a Senior Member of the IEEE for 2018.

IEEE is the world’s largest technical professional organization dedicated to advancing technology for the benefit of humanity. With more than 400,000 members in over 160 countries, IEEE is a trusted voice for engineering, computing, and technology information around the globe. Randy has been a member of IEEE for 22 years.

Senior Member is the highest professional grade of the IEEE for which a member may apply. It requires extensive experience, and reflects professional accomplishment and maturity. Only 10% of our more than 400,000 members have achieved this level.

Randy provides regulatory guidance to GreenSoft and GreenSoft customers, and is the presenter for GreenSoft's educational webinars. This latest recognition by IEEE comes in addition to Randy's other accomplishments, such as the Distinguished Committee Service Award from IPC, and recognition for his work with the IEEE Electromagnetic Compatibility society and IEEE Product Safety Society.

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EU REACH

October 17, 2018 | Written by GreenSoft Technology, Inc.

Application of the EU REACH Regulation to Glass

SVHCs present in glass or ceramic frit are generally exempt from EU REACH communication obligations

EU-REACH

Under the EU REACH regulation, manufacturers may be permitted to apply certain exemptions to substance restrictions for certain specific substances and applications. Substances incorporated into ceramic or glass frit is one such application that has been exempted from Annex V article 7 of the REACH regulation by the European Commission.

Annex V of the REACH regulation addresses the obligation to register and communicate the presence of a Substance of Very High Concern (SVHC) within a product or article. Under the REACH regulation, glass is considered as a UVCB substance (substance of unknown or variable composition, complex reaction products or biological materials).

While SVHCs are commonly used to produce glass, the SVHCs are chemically transformed into the glass substance during the melting process. The glass substance is subsequently processed into articles. In these cases, the SVHCs are completely transformed and not present as such in the final glass-containing article.

Consequently, there is no obligation to notify or to communicate information down the supply chain under EU REACH. This was confirmed in a document released by the European Chemicals Agency (ECHA) in 2016.

More information about the nature and composition of glass and how the EU REACH regulation applies to glass can be found on the European Glass Alliance website.

With the addition of lead to the SVHC Candidate list on 27 June 2018, and the common use of lead in glass frit in EU RoHS compliant components (under EU RoHS exemption 7c-I), there has been some confusion in the industry about whether these applications are subject to EU REACH communication obligations. They are not.

Keep in mind that the application of the EU RoHS 7c-1 exemption does not automatically exempt the producer from requirements to communicate the presence of lead as an SVHC under the REACH regulation. If the part has any other applications of lead outside of the glass application, these other applications of lead would need to be evaluated for potential communication and notification obligations.

For example, the part could claim 7c1 (lead in glass) and 7a (lead in high melting point solder). In that case, the lead in the solder would still need to be considered.

GreenSoft Can Help Ensure Your Company is in Compliance with REACH

GreenSoft helps companies manage REACH compliance with a process that includes data collection, data validation, and report generation. We can also help with sourcing replacement parts for non-compliance parts, or recommending replacement suppliers for non-compliant or non-responsive suppliers. Learn more about our REACH compliance services here or get started with a FREE Risk Analysis/BOM Scrub.

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White Paper

October 4, 2018 | Written by GreenSoft Technology, Inc.

Compliance Management Service Provider Comparison White Paper

Get our new white paper comparing compliance service providers versus contract manufacturers

WP-gs-vs-ems-or-cmA new informational white paper is available to download in our White Paper Library.

"Compliance Management Through a Compliance Service Provider Versus an Electronic Manufacturing Service (EMS) or Contract Manufacturer (CM)" compares the services provided by third party compliance service providers like GreenSoft with the services provided by EMS or CM companies.

The white paper covers topics including:

  • Explanation of the compliance document collection service offered by many EMS/CM companies
  • Explanation of the substance data collection and analysis service offered by compliance service providers
  • Which option is recommended for various environmental regulations or company goals

The white paper provides recommendations on which service to choose for regulations including EU RoHS, EU REACH, and California Proposition 65.

When you need to pick a service for your small or large compliance projects, this paper can help you make a decision between an EMS/CM company or a compliance service provider, and justify that choice to your company management.

Download the white paper for free in our White Paper Library.

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