The Association of Manufacturers and suppliers of Power Systems and ancillary equipment
AMPS
AMPS is the trade association and industry voice for the UK’s world-leading diesel and gas-engine power generating sector and associated businesses.
ID: 503709734995-10
Lobbying Activity
Response to Exemptions under RoHS for lead in glass or ceramic of electrical and electronic components
10 Feb 2025
As The Association of Manufacturers of Power generating Systems (AMPS) We welcome the opportunity to provide feedback on the European Commissions draft amendment to directive 2011/65/EU (Regarding exemption for lead in glass or ceramic components) Ref. Ares(2025)216368 Our members would be directly affected by the removal of exemption 7c within Category 9 and 11 of the RoHS Directive. The proposal for reducing existing amendments to 2 years maximum is concerning. In short whilst there may be some alternative materials available within the Supply Chain, this is by no means confirms the ability to full substitution of materials. Where material substitutions are available, there are consequences to industry supply chains in both cost and lead time and functionality. As an Industry body representing Electrical power generation Industry, the concern over not only availability and revalidation for electronic components, but the suitability of substitute parts is alarming. The technical assessment within this delegated directive support that shortened expiry dates will not be beneficial. Already supported that current exemption is justified: "(i) are not suitable and cannot be fabricated into lead-free components that could be used in the same applications; or (ii) provide an inferior reliability leading to malfunctions that would not be acceptable in the respective EEE." Whilst AMPS fully support the ultimate objective of the removal of lead in electronic components or any material, it is the impact that shortened expiry dates have with relation to Supply Chain and validation that are a concern. The big concern for electronics both as category 9 and as used in category 11 is that lead free electronic components have to be assessed for stability of operation and performance, as the consequential impact to safety of end-users and the general public has to be confirmed. It is recommended that a longer period of exemption is allowed such that both the supply chain feasibility and the impact assessment to category 11 equipment can be conducted.
Read full responseResponse to Exemptions under RoHS for lead as an alloying element in steel, aluminium and copper
10 Feb 2025
As The Association of Manufacturers of Power generating Systems (AMPS) We welcome the opportunity to provide feedback on the European Commissions draft amendment to directive 2011/65/EU (Regarding exemption for lead as an alloying element in steel, aluminium and copper) Ref. Ares(2025)216290 Our members would be directly affected by the removal of exemptions 6a, 6b and 6c within Category 9 and 11 of the RoHS Directive. The proposal for reducing existing amendments to 2 years maximum is concerning. In short whilst there may be some alternative materials available within the Supply Chain, this is by no means confirms the ability to full substitution of materials. Where material substitutions are available, there are consequences to industry supply chains in both cost and lead time. As an Industry body representing Electrical power generation Industry, substitutions of metallic materials will also introduce lengthy re validation in some instances. Furthermore, the technical conclusions within this delegated directive support that shortened expiry dates will not be beneficial. As stated, barely any progress made on substituting lead in steel for machining purposes since the review in 2015 There are similarly themed conclusions for both aluminium and copper. Whilst AMPS fully support the ultimate objective of the removal of lead in materials, it is the impact that shortened expiry dates have with relation to Supply Chain and validation that are a concern. It is recommended that a longer period of exemption is allowed such that both the supply chain feasibility and the impact assessment to category 11 equipment can be conducted.
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