RoHS2.0 Exemption Clause Update

2019-11-19 00:00:00

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On 5 November 2019, the Official Journal of the European Union published Directives (EU) 2019/1845 and (EU) 2019/1846 amending Directive 2011/65/EU with the addition of Article 43 to Annex III of RoHS 2.0 on the exemption clause for lead in the solder of certain rubber components used in engine systems (2-ethylhexyl) phthalate and Article 44 on the exemption of lead in solder of internal combustion engine sensors, actuators and engine control units. It will be implemented in EU member states from May 1, 2020.

New terms

article

exempt

Scope and date of application

Bis(2-ethylhexyl) phthalate in rubber parts of engine systems in equipment designed for use not solely by consumers, plastics not in human mucosal contact or prolonged human skin contact, and the concentration values of bis(2-ethylhexyl) phthalate do not exceed:

(a) 30% of the weight of the rubber, used for:

(I) Gasket coating

(ii) solid rubber gaskets; or

(iii) Rubber parts connected to an engine and consisting of at least three parts that operate electrically, mechanically or hydraulically.

(b) 10% of the weight of the rubber, for rubber parts not mentioned in clause (a).

For the purposes of this entry, "prolonged contact with human skin" means continuous contact for more than 10 minutes or intermittent contact for more than 30 minutes per day.

Applicable to Class 11 products with an expiry date of 21 July 2024.

Lead in solder in internal combustion engine sensors, actuators and engine control units within the scope of Regulation (EU) 2016/1628 of the European Parliament and of the Council of the European Union, installed in equipment for use in fixed positions, designed for professionals, but also for non-specialists.

Applicable to Class 11 products with an expiry date of 21 July 2024.

DReasons for exemption from EHP

The use of DEHP in rubber components if its design uses are not limited to O-rings, seals, shock absorbers, gaskets, hoses, seals and lid plugs in engine systems for consumer use, including exhaust and turbochargers.

DEHP is added as a plasticizer to rubber materials to enhance the flexibility of rubber. Rubber components are used as flexible connections between engine system components to prevent leaks, seal engine components, and prevent vibration or keep out dust and liquids during the life of the engine.

Currently, there is no DEHP-free alternative on the market that can be added to rubber to provide sufficient reliability for engine applications that require long life and special properties such as resistance to contact materials (e.g., fuels, lubricants, coolants, gases or dust), temperature and vibration properties.

Due to the lack of reliable alternatives, it remains scientifically and technically impractical to replace or eliminate DEHP for some rubber components used in engine systems.

EQO has an experienced team of experts and a complete laboratory, committed to providing customers with testing services including electrical and electronic products hazardous substances, material analysis, etc., and has rich experience in quality assessment programs, regulations and standards training, consulting, etc., and can provide customers with one-stop service! Helping customers be more successful.

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RoHS2.0 Exemption Clause Update