Barco
Barco is a global technology leader that develops networked visualization solutions for the entertainment, enterprise and healthcare markets.
ID: 170365845611-52
Lobbying Activity
Response to Exemptions under RoHS for lead in glass or ceramic of electrical and electronic components
6 Feb 2025
The proposed expiry dates (31 December 2026 or 2027) are very short. While we appreciate the difficulty of managing the RoHS file, the long delay of the European Commission in assessing the requests, submitted in 2020, should not result in deadlines so short to put an extreme burden on companies. This is particularly noticeable for exemption whose wording has been changed. For instance, the reduction of the allowed concentration for 6b-III or the split of exemption wording such as 7a and 7c. We believe it is worth reminding that the companies taking an active role in the RoHS exemption process are only a small number compared to the majority of the EU and global supply chain that is only informed about a new exemption wording at the time of its official publication on the OJ. Companies manufacturing complex electronic devices are at the end of very long and complexes supply chain. The difficult and time-consuming reliability and safety testing of alternatives can only start once the supply chain delivers the parts and components using the alternatives. This normally happens six months before the deadline for the restriction (normal business practice) For this reason, in the past, both RoHS and REACH always granted more time to the sector compared to other sectors (not mentioning IVDs or category 9 EEE): o RoHS entry into force: 2006 for all categories 2014 for Medical devices o 2015 restriction of phthalates for all categories 2018 for medical devices o 5 years max duration of exemptions for all categories 7 years for medical devices For this reason, we request that the deadlines proposed in the draft acts are amended to ensure at least 2 years are granted to manufacturers. Exemption 6b Category 8 has been forgotten The wording of exemption 6b, 6bI, 6bII and 6bIII seems to have missed category 8 medical devices. According to our interpretations, medical devices will have to switch to 0,3% lead aluminium, 6 months before other categories as category 8 is only mentioned in 6b. In fact, exemption 6b expires 12 months after the publication while for other categories the expiration is set to 18 months. In addition, the additional requirement that any lead in the aluminium should originate from scrap recycling adds a new serious obstacle. According to our discussion with the supply chain, no supplier is able to provide assurance about the origin of the aluminium and its lead content. It is indeed a new requirement, involving tracking activities and new documentation to be generated that will require a lot of time. With such a short deadline (18 months if we assume 12 was not intended) many components may not be usable in manufacturing just because the relative suppliers are not able to ascertain and document their origin, even if the lead content is below 0,3%. Considering the risk for availability of products, we believe granting 2 years, in line with the industry manufactures is a wise choice.
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