RoHS Exemption FAQ

What You Need to Know

What is RoHS?

Restriction of Hazardous Substances Directive (RoHS) is the regulatory framework adopted by the European Union (EU) in the early 2000s restricting the use of certain hazardous substances in electrical and electronic equipment. The intent of the rule is to limit the amount of hazardous chemicals that may end up in landfills at the end of the product’s useful life.  

How does RoHS impact the aluminum industry?
To ensure that nontoxic electrical and electronic equipment wasn’t integrated into the market, the European Union sanctioned Directive 2011/65/EU in 2011. With respect to the aluminum industry, this Directive firmly held member states and stakeholders to limit lead (Pb) content in aluminum alloys that is used in electronic equipment to 0.1% by weight. However, that limit was fixed at 0.4% Pb by weight under the long-standing exemption 6b which was set to expire in July 2016. This would have required electrical component manufacturers to return to Pb limits of 0.1% by weight in aluminum alloys. Consequently, products were commanded to be in compliance with the new Pb limits on the date the exemption expires or they would not be eligible for sale in the EU.

How did the aluminum industry respond?
A petition to extend exemption 6b for aluminum alloys under RoHS was collaboratively submitted in January, 2015 by the European Aluminium Association and U.S Aluminum Association with the assistance of countless stakeholders within the industry. In particular, the European Aluminium Association presided over the work group that revised the request to prolong the exemption.

At its core, the petition not only highlights the significance “intentionally-introduced Pb” has on the manufacturing of structural aluminum components, but also the technical inadequacy of removing “unintentionally-introduced Pb” from the aluminum recycling process. Although there has recently been lead-free aluminum alloys available on the market, the reliability of these substitutes (and those similar) still require further examination and assessment.

What is the current status of RoHS in Europe?
After due consideration, The European Commission accordingly amended the former regulations of Directive 2011/65/EU and adopted Directive 2018/740/EU - extending exemption 6b. The newly modified exemption was published in the Journal of the European Union on May 18, 2018 and will enter into force June 7, 2018.

The table below illustrates the new, upcoming expiration date of exemption 6b but will vary depending on the category of products specified in the European Waste Electrical and Electronic Equipment Directive (WEEE).

What does this mean for the aluminum industry?
Moving forward, members of the EU are required to adopt and publish necessary laws, regulations and administrative provisions by June 30, 2019 in order to be in compliance with Directive 2018/740/EU. These provisions will take effect on July 1, 2019.

Correspondingly, the aluminum industry must embrace the obligatory changes determined by EU member states in order to be considered an safe and eligible product on the European market.

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