New RoHS Exemption Consultation

There is a new consultation for RoHS exemptions going on now. It started on Friday, Nov. 9. This stakeholder consultation runs for 12 weeks from now through Feb. 1.

From Philips to Toshiba Semiconductor and Xerox, the list of interested stakeholders in the RoHS exemptions assessment is formidable, although a bit thinner than you’d expect. Note: some companies chose to remain unidentified on the public list.

Four exemption requests are covered in this new consultation:

  1. Exemption request 12 “Leaded solder utilized in stacked, area array electronics packaging within ionizing radiation detectors including CT and X-ray”
  2. Exemption request 13 “Lead in platinized platinum electrodes for measurement instruments”
  3. Exemption request 14 “Lead in solders for the ignition module and other electronic engine controls mounted directly on or close to the cylinder of hand-held engines (classes SH: 1, SH: 2, SH: 3 of 2002/88/EC)”
  4. Exemption request 15 “Hand crafted luminous discharge tubes (HLDT) used for signs, decorative or general lighting and light-artwork”

The new RoHS project hopes to minimize compliance burdens.

Go to http://rohs.exemptions.oeko.info/index.php?id=152 for guidance on the new exemption consultation. [A good overview of RoHS 2 is here.]

Next steps Unconfidential information submitted during the consultation will be posted on the EU CIRCA website (Browse categories > European Commission > Environment > RoHS 2012 Exemptions Review, at top left, click on “Library”). Further exchange with stakeholders will be held after the consultation has ended for those issues where further need for information and / or need for (technical) discussion has been identified.

My 2 cents It would behoove most companies to be stakeholders in this type of discussion. But the fact is that we’re all busy right now, if not “stretched.” You have to choose your battles wisely from a time management point of view— which is the main reason why every major RoHS-affected company isn’t listed as a stakeholder.

For more on this consultation, go to http://rohs.exemptions.oeko.info/.

Also, a Thank You to John Sharp of TriQuint Semiconductor, Inc for passing along this information.  Kudos.

About Kal

Kal Kawar, CIH, PE, has a bachelor's in chemical engineering and a master's in industrial hygiene. His professional experience includes serving as staff industrial hygienist for IBM's New York semiconductor manufacturing facility, and as industrial hygienist for IBM’s US headquarters. Now executive vice president of Actio, Kal taps more than 20 years' worth of chemical engineering, industrial hygiene, and environmental engineering experience. His far-reaching expertise with global regulatory challenges created by EPA, TSCA, REACH, RoHS, WEEE – and hundreds of others – aid in developing Actio software solutions for MSDS management, raw material disclosure compliance, and product stewardship in a supply chain.
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