The European Commission has proposed a new exemption under Directive 2011/65/EU (RoHS Directive) for the use of lead as an alloying element in steel, aluminium, and copper in electrical and electronic equipment (EEE). This exemption addresses technical and scientific challenges in substituting lead, aiming to balance environmental protection with industrial feasibility. Stakeholder feedback is open until 10 February 2025, with final adoption planned for the third quarter of 2025.
Background on RoHS Directive and Lead Exemptions
The RoHS Directive limits hazardous substances in EEE to protect human health and the environment. Lead, a restricted substance under Annex II of the directive, is permitted in limited applications under Annex III exemptions. The current exemption renewal addresses lead in steel for machining, galvanised steel, aluminium alloys, and copper alloys.
Proposed Changes and Justifications
The proposed exemptions reflect advancements in recycling and manufacturing while acknowledging technical limitations:
- Steel: Lead improves machinability in steel, particularly in galvanised components. Substitutes for certain applications remain impractical.
- Aluminium: Lead content in recycled aluminium scrap is expected to decrease over time. A new exemption limits lead to 0.3% in casting alloys while phasing out lead for machining purposes, except for specific industrial applications.
- Copper: Leaded copper alloys offer essential properties like conductivity and corrosion resistance. No immediate alternatives are reliable across all applications.
Public Consultation and Next Steps
The feedback period for the draft directive runs until 10 February 2025. Stakeholders are encouraged to contribute to shaping these regulations, which aim to provide transitional periods for industries to adopt sustainable practices.