The European Commission is seeking public feedback on a proposed amendment to the RoHS Directive, which governs the use of hazardous substances in electrical and electronic equipment. This initiative centres on the exemption for lead in high melting temperature solders, an essential component in many electronic devices. The feedback window is open from 13 January 2025 to 10 February 2025, providing stakeholders an opportunity to shape the regulation.
The Context Behind the Proposed Amendment
The RoHS Directive currently permits the use of lead-based solders containing at least 85% lead by weight, under specific exemptions. These exemptions are granted when alternatives are unavailable or when substitutes may result in greater environmental or health impacts.
A 2024 technical and scientific study suggested dividing the exemption into seven sub-categories, each addressing distinct technical requirements, such as internal interconnections, hermetic sealings, and first and second-level solder joints. This segmented approach aims to improve clarity and promote the development of lead-free alternatives.
Sub-Categories of Lead Use in Solders
The proposed amendment categorises the exemption into seven use cases, including:
- Internal interconnections: Essential for die attachment in semiconductor assemblies operating under high voltage and current.
- Hermetic sealing: Required for devices in extreme environments, such as infrared lamps and audio transducers.
- First and second-level solder joints: Used for attaching components in printed circuit boards and subassemblies.
Justifications for the Exemption
Lead-based solders are essential for applications where no reliable or cost-effective alternatives exist. They offer high thermal and electrical conductivity, corrosion resistance, and durability, especially in harsh environments. While progress has been made with lead-free options, these alternatives are not yet viable for all applications.
Implications and Future Actions
The European Commission proposes a phased approach, granting short-term renewals for the exemptions, set to expire between 2026 and 2027. This extension allows industries time to adapt to alternatives while maintaining compliance with environmental and health standards. Public feedback will guide the final directive, which is expected to be adopted by the third quarter of 2025.
