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EU RoHS Exemptions # 6 for Lead in Metal Alloys

EU RoHS Exemption – Get Ahead of Your Lead!

What is EU RoHS?

RoHS is a term used to refer to the Directive 2011/65/EU of the European Parliament and of the Council. This directive outlines one’s obligation to restrict the use of certain hazardous substances in electrical and electronic equipment. However, an EU RoHS exemption is possible. To learn more about RoHS and ensuring compliance, look at our Europe RoHS Compliance page!

RoHS Regulated Substances

The EU RoHS defines general concentration thresholds for:

 

  • Lead (Pb) and lead compounds
  • Cadmium (Cd) and cadmium compounds
  • Mercury (Me) and mercury compounds
  • Hexavalent Chromium (Cr6+) and hexavalent chromium compounds
  • Polybrominated biphenyls (PBBs)
  • Polybrominated diphenyl ethers (PBDEs)
  • Butyl benzyl phthalate (BBP) – CAS # 85-68-7
  • Di-n-butyl phthalate (DBP) – CAS # 84-74-2
  • Di(2-ethylhexyl) phthalate (DEHP) – CAS # 117-81-7
  • Diisobutyl phthalate (DIBP) – CAS # 84-69-5
RoHS restrictions in products

However, exemptions for these restrictions are important to monitor as an electronic products designer. This article will explain and simplify all one needs to know about the exemptions, family 6, for lead concentrations in metal alloys.

RoHS Exemptions for Lead-Bearing Metal Alloys

Table 1: Lead Concentrations in Metal Alloys - Family 6 RoHS Exemptions

Exemption #DescriptionScope and Expiration Dates
6(a)Lead as an alloying element in steel for machining purposes and in galvanized steel containing up to 0.35 % lead by weight.Applies to categories 8, 9 and 11. Expires on: —21 July 2024 for category 11 (other EEE).

6(a)-I

Lead as an alloying element in steel for machining purposes containing up to 0.35 % lead by weight and in batch hot dip galvanized steel components containing up to 0.2 % lead by weight.

Applies to categories 1 to 7 and 10.

6(b)

Lead as an alloying element in aluminium containing up to 0.4 % lead by weight, provided it stems from lead-bearing aluminium scrap recycling.

Applies to categories 1 to 7 and 10.
6(b)-I

Lead as an alloying element in aluminium containing up to 0.4 % lead by weight, provided it stems from lead-bearing aluminium scrap recycling.

Applies to categories 1 to 7 and 10.

6(b)-II

Lead as an alloying element in aluminium for machining purposes with a lead content up to 0.4 % by weight.

Applies to categories 1 to 7 and 10.

6(c)

Copper alloy containing up to 4 % lead by weight.

Applies to categories 1-7, 10 and 11. Expires on: — 21 July 2024 for category 11 (other EEE).

The complete list of EU RoHS General Exemptions (Annex III) can be found on our Europe RoHS Compliance page.

RoHS Terminology

Category: Refers to the 11 different categories of EEE covered by the Directive 2011/65/EU

1. Large household appliances.
2. Small household appliances.
3. IT and telecommunications equipment.
4. Consumer equipment.
5. Lighting equipment.
6. Electrical and electronic tools.
7. Toys, leisure, and sports equipment.
8. Medical devices.
9. Monitoring and control instruments including industrial monitoring and control instruments.
10. Automatic dispensers.
11. Other EEE not covered by any of the categories above.

EEE: Acronym for Electrical and Electronic Equipment

Alloying element: An alloy is a substance made from combining two or more metals, therefore an alloying element is one of these metals. Every alloy has its own chemical composition.

% by Weight: This can be interpreted as the quantity of a given substance (ex. In grams) for every 100 units (ex. grams) of the total mixture.

Galvanizing: The process of coating a steel/iron product with zinc.

Batch hot-dip: This is a galvanizing process where the steel/iron product is immersed in a bath of liquid zinc.

RoHS Exemptions for Metal Alloys – What Do They Mean?

RoHS Exemption 6(a)

Impacted product:
Steel used for machining, or galvanized steel.

Applicable product categories:

  • Medical devices [cat. 8]
  • Monitoring and control instruments including industrial monitoring and control instruments [cat.9]
  • Other EEE not covered by any of the categories mentioned in Annex I of EU RoHS [cat. 11].

Exemption:
The steel alloy can contain a maximum of 0.35% lead by weight, as opposed to the standard 0.1% granted by the EU RoHS.

Steel RoHS exemption

RoHS Exemption 6(a)-I

Impacted product:
Steel used for machining, or steel galvanized by means of batch hot-dip.

Applicable product categories:

  • Large household appliances [cat. 1]
  • Small household appliances [cat. 2]
  • IT and telecommunications equipment [cat. 3]
  • Consumer equipment [cat. 4]
  • Lighting equipment [cat. 5]
  • Electrical and electronic tools [cat. 6]
  • Toys, leisure and sports equipment [cat. 7]
  • Automatic dispensers [cat. 10]

Exemption:
A steel alloy used for machining can contain a maximum of 0.35% lead by weight, and steel components galvanized by batch hot-dip can contain a maximum of 0.20% lead by weight. Both replacing the standard 0.1% granted by the EU RoHS.

RoHS Exemption 6(b)

Impacted product:
Aluminum.

Applicable product categories:

  • In-vitro diagnostic medical devices [cat. 8]
  • Industrial monitoring and control instruments [cat. 9]
  • Other EEE not covered by any of the categories mentioned in Annex I of EU RoHS [cat. 11]

Exemption:
The aluminum component can contain a maximum 0.4% lead by weight, as opposed to the standard 0.1% granted by the EU RoHS.

RoHS exemption Aluminum

RoHS Exemption 6(b)-I

Impacted product:
Lead-bearing aluminum scrap recycling.

Applicable product categories:

  • Large household appliances [cat. 1]
  • Small household appliances [cat. 2]
  • IT and telecommunications equipment [cat. 3]
  • Consumer equipment [cat. 4]
  • Lighting equipment [cat. 5]
  • Electrical and electronic tools [cat. 6]
  • Toys, leisure and sports equipment [cat. 7]
  • Automatic dispensers [cat. 10]

Exemption:
In the case where recycled aluminum is used to produce components and lead is already present as an alloying element, a maximum of 0.4% by weight of lead is allowed. This concentration threshold cumulates prior and future lead concentrations by weight. This exemption replaces the standard 0.1% granted by the EU RoHS.

RoHS Exemption 6(b)-II

Impacted product:
Aluminum used for machining.

Applicable product categories:

  • Large household appliances [cat. 1]
  • Small household appliances [cat. 2]
  • IT and telecommunications equipment [cat. 3]
  • Consumer equipment [cat. 4]
  • Lighting equipment [cat. 5]
  • Electrical and electronic tools [cat. 6]
  • Toys, leisure and sports equipment [cat. 7]
  • Automatic dispensers [cat. 10]

Exemption:
The aluminum alloy cannot contain more lead than 0.4% by weight as opposed to the standard 0.1% granted by the EU RoHS.

RoHS Exemption 6(c)

Impacted product:
Copper.

Applicable product categories:

  • Large household appliances [cat. 1]
  • Small household appliances [cat. 2]
  • IT and telecommunications equipment [cat. 3]
  • Consumer equipment [cat. 4]
  • Lighting equipment [cat. 5]
  • Electrical and electronic tools [cat. 6]
  • Toys, leisure and sports equipment [cat. 7]
  • Automatic dispensers [cat. 10]
  • Other EEE not covered by any of the categories mentioned in Annex I of EU RoHS [cat. 11].

Exemption:
The copper alloy cannot contain more lead than 4% by weight as opposed to the standard 0.1% granted by the EU RoHS.

Lead Concentrations in Metal Alloys According to Specifications

The following tables contain examples of lead-bearing metal alloys and whether they comply with the EU RoHS.

These are not exhaustive tables of steel, aluminum, and copper alloys. The data should only be used as an example; producers have the responsibility to monitor and verify that the lead concentrations in their products align with the RoHS standard or its exemptions.

Coating and finishes should also be considered as additional homogeneous materials. For example, some zinc finishes don’t comply with EU RoHS.

Table 2: Examples of Steel Alloys and Their Compliance

Alloy

(AISI/ANSI/ASTM/SAE #)

Lead concentration

(% by Weight)

 Compliant Without Exemption

Compliant 

Applicable Exemptions 

6(a) or 6(a)-I

201, A240, 303, 304, 316, 410, 1119, 1139, 1049, 1116, 1132, 1137, 1141, 1145, 1151, 1050, 1109, 1117, 1118, 1140, 1146, 1212, 1052, 1110, 11440Lead Free –
11L19, 11L39, 10L49, 11L16, 11L32, 11L37, 11L41, 11L45, 11L51, 10L50, 11L09, 11L17, 11L18, 11L40, 11L46, 12L12, 10L52, 11L10, 11L440.15 – 0.35 –[Dependent on the product’s category]

Notes

  • AISI stands for American Iron and Steel Institute.
  • ANSI is the American National Standards Institute.
  • ASTM means American Society for Testing and Materials.
  • SAE is the Society of Automotive Engineers.
  • For steel alloys, compliance can be obtained either with or without exemption. In this case, lead-content thresholds for compliance will depend on the product’s category (one of the 11 detailed above). If the product is not applicable for the 6a or 6a-I exemptions, standard RoHS thresholds must instead apply.
  • Stainless steel without finish like #201 or 410 are EU RoHS compliant without exemption.
  • Standard ANSI steels are referred to by a 4-digit number and do not contain lead. When lead is introduced into the steel to improve its machinability, a capital “L” is written between the 2nd and 3rd number as shown, for example, in the steel 1119 (i.e., 11L19).

Table 3: Examples of Aluminum Alloys and Their Compliance

Alloy

(RID or UNS #)

Lead concentration

(% by Weight)

Compliant Without Exemption

Compliant – Applicable Exemptions

6(b), 6(b)-I or 6(b)-II

Non-Compliant
1050, 1050A, 1060, 1065, 1070, 1070A, 1080, 1080A, 1085, 1090, 1098, 1100, 1110, 1150, 1230, 1235, 1275, 1450 0 Lead-Free
2001, 2007A, 2007B, 5052 (5052-H32), 6061, 6063 0 – 0.1 Traces of lead
2015, 2028A, 2028B 0.1 – 0.4 [Dependent on the product’s category]
6262, 6012, 2007, 2030, 2005, 5058 > 0.40 [For all product categories]

Notes

  • The lead concentrations for these alloys are referenced from The Aluminum Association.
  • RID is the acronym for the Registered International Designation.
  • UNS refers to Unified Numbering System.

Table 4: Examples of Copper Alloys and Their Compliance

Alloy

(UNS #)

Lead concentration

(% by Weight)

Compliant Without Exemption

Compliant – Applicable Exemption

6(c)

Non-Compliant
C10100, C11025, C11040, C11045, C12500, C12510, C12700, C12800, C12900, C13000, C14180, C14181, C14410, C14425, C14510, C14710, C14720, C15710, C15715, C15720, C15725, C15735, C15760, C15815, C18200, C18500, C18835, C18900, C18980, C19000, C19002, C19005, C19022, C19024, C19026, C19030, C19040, C19050, C19100, C19170, C19240, C19250, C19300, C19400, C19419, C19500, C19700, C19710, C19720, C19750, C20500, C21000, C22000, C22600, C23000, C23030, C23400, C24000, C25000, C25600, C26000, C26100, C26130, C26200, C26800, C27000, C27200, C27250, C27400, C27550, C28000, C28200, C28300, C28310, C28320, C28330, C28550, C40410, C40500, C40800, C40810, C40820, C40850, C40860, C40900, C40950, C41000, C41100, C41110, C41120, C41125, C41300, C41500, C41900, C42100, C42200, C42210, C42220, C42230, C42300, C50100, C50200, C50500, C50580, C50590, C50700, C50705, C50715, C50725, C50780, C50800, C50900, C51000, C52600, C52900, C60700, C60800, C61000, C61300, C61400, C61470, C61500, C61550, C61800, C61810, C61900, C77300, C77310, C77400, C81500, C81540, C82000, C82400, C82500, C82510, C89940, C90280, C90400, C90410, C90420, C90430, C94700, C95210, C99770, C99771, C99780 0 – 0.1 Traces of lead
C35340, C35600, C36000, C36010, C36300, C36500, C36600, C36700, C36800, C37000, C17300, C17455, C17465, C18700, C19140, C19150, C19160, C24080, C26380, C27450, C27451, C27453, C27460, C28340, C28500, C28580, C29800, C31000, C31200, C31400, C31600, C32000, C32500, C32510, C33000, C33100, C33200, C33500, C33530, C34000, C34200, C34400, C34500, C34700, C34800, C35000, C35300, C35330, C37100, C37700, C48640, C48645, C49080, C53200, C53400, C53800, C54400, C64110, C66100, C79830, C79860, C79900, C83300, C83400, C83420, C99350, C99700, C99750 0.1 – 4 [For all product’s categories]
C83800, C84400, C84410, C84500, C84800, C93200, C93400, C93500, C93600, C93700, C93720, C93800, C93900, C94000, C94100, C94300, C94310, C94320, C94330, C94400, C94500, C97300, C97400, C98200, C98400, C98600, C98800, C98820, C98840 > 4 [For all product categories]

The lead concentrations for these alloys are referenced from the Copper Development Association Inc.

The laws, regulations, and exemptions regarding the environmental compliance of your products are ever-changing, and therefore important to continuously monitor. There are many more RoHS exemptions in the directive’s annexes III and IV aside from lead concentrations in metal alloys.

We are here to make compliance achievable; reach out to the Enviropass team for any questions regarding the EU RoHS regulations!