International Wrought Copper Council
IWCC
The IWCC is the global association for the copper and copper alloy fabricating industry.
ID: 254829994041-90
Lobbying Activity
Response to Exemptions under RoHS for lead as an alloying element in steel, aluminium and copper
10 Feb 2025
The International Wrought Copper Council (IWCC) is the global association for the copper and copper alloy semis fabricating industry. In Europe, the IWCC has established a Brass Rod Committee of its members in accordance with IWCC Guidelines comprising a number of European brass rod manufacturers. Brass rods, wires and profiles account for the vast majority of lead containing copper alloys used in electric/electronic components covered by RoHS. The IWCC Brass Rod Committee supports the current Draft Delegated Directives approach to maintain the 4% exemption for lead in copper alloys for the current period. Significant progress from industry has been and continues to be made towards developing lead-free solutions, although these do not yet fully replicate all the functions to the same level of lead in brass. Any immediate move to end the exemption completely could also result in short-term unintended consequences for the circular economy and recycling loops, and for the environmental footprint of brass products produced in Europe. It should also be noted that the new expiry date of 31 December 2026 provides only limited time for industry to prepare a submission for the next review, which needs to be provided in May 2025. The IWCC Brass Rod Committee notes that the brass rod industry in Europe continues to proactively develop and bring to the market lower-lead and lead-free brass alloys to meet regulatory requirements. The ongoing development of new lower-lead and lead-free brass alloys is likely to mean these can replicate nearly all the functional properties of standard lead-containing brass. To do this while minimizing the unintended consequences described above requires a step-by-step approach to reducing the amount of lead in standard brass alloys across the industry over time, and for this to be clearly communicated to all actors in advance. The IWCC Brass Rod Committee seeks to engage with EU regulatory bodies including DG Environment and ECHA as soon as possible on how this step-by-step reduction of lead in brass could best be achieved as part of the next revision process.
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