The RoHS Directive for Electronics: Exceptions

June 14, 2010


RoHS Directive is far-reaching and penetrates the manufacturing sector and every supply chain.  We have written about RoHS an in this blog previously, including FAQ About RoHS Compliance.  We're also something of a data-library here for general RoHS information; given that our software guarantees manufacturers compliance with RoHS, our expertise has to be sharp, current, and even pre-emptive.  So we invite you to share in our wealth of information.  Feel free to share yours in return (comments).


Got RoHS?  You may not need to...

There are exceptions, and exemptions, to every Rule. In this case, sometimes it helps to understand where a directive like RoHS doesn't apply in order to get a better understanding of the rule in the big picture sense.

To review, the electronics industry already has in place:

Manufacturers, of course, must understand and manage the requirements of the RoHS Directive to ensure that their products, and their components, comply.  Yes, RoHS is enforced.   Yes, RoHS is everywhere.

As ubiquitous as RoHS is becoming, there are exceptions to the rule.  Sometimes - and here's where it gets complicated - there are exemptions for use of  mercury, lead, cadmium (see SVHC list here) in the manufacture of electronics and electronic devices. 

Below is a list worth browsing.  It might be too much detail for most, but do review it to get a feel.  Then, you may want to keep it handy for reference. 


RoHS Exemptions as of March 2010:


  1. Mercury in compact fluorescent lamps not exceeding 5 mg per lamp
  2. Mercury in straight fluorescent lamps for general purposes not exceeding: — halophosphate 10 mg
  3. Mercury in straight fluorescent lamps for general purposes not exceeding:  — triphosphate with normal lifetime 5 mg
  4. Mercury in straight fluorescent lamps for general purposes not exceeding: — triphosphate with long lifetime 8 mg
  5. Mercury in straight fluorescent lamps for special purposes
  6. Mercury in other lamps not specifically mentioned in this Annex
  7. Lead in glass of cathode ray tubes, electronic components and fluorescent tubes
  8. Lead as an alloying element in steel containing up to 0,35 % lead by weight, aluminum containing up to 0,4 % lead by weight and as a copper alloy containing up to 4 % lead by weight
  9. Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead)
  10. Lead in solders for servers, storage and storage array systems, network infrastructure equipment for switching, signaling, transmission as well as network management for telecommunications
  11. lead in electronic ceramic parts (e.g. piezoelectronic devices)
  12. Cadmium and its compounds in electrical contacts and cadmium plating except for applications banned under Directive 91/338/EEC (1) amending Directive 76/769/EEC (2) relating to restrictions on the marketing and use of certain dangerous substances and preparations
  13. Hexavalent chromium as an anti-corrosion of the carbon steel cooling system in absorption refrigerators
  14. DecaBDE in polymeric applications. Exemption ended 30 June 2008
  15. Lead in lead-bronze bearing shells and bushes
  16. Lead used in compliant pin connector systems
  17. Lead as a coating material for the thermal conduction module c-ring
  18. Lead and cadmium in optical and filter glass
  19. Lead in solders consisting of more than two elements for the connection between the pins and the package of microprocessors with a lead content of more than 80 % and less than 85 % by weight
  20. Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit Flip Chip packages
  21. Lead in linear incandescent lamps with silicate coated tubes
  22. Lead halide as radiant agent in High Intensity Discharge (HID) lamps used for professional reprography applications
  23. Lead as activator in the fluorescent powder (1 % lead by weight or less) of discharge lamps when used as sun tanning lamps containing phosphors such as BSP (BaSi2O5:Pb) as well as when used as specialty lamps for diazoprinting reprography, lithography, insect traps, photochemical and curing processes containing phosphors such as SMS ((Sr,Ba)2MgSi2O7:Pb)
  24. Lead with PbBiSn-Hg and PbInSn-Hg in specific compositions as main amalgam and with PbSn-Hg as auxiliary amalgam in very compact Energy Saving Lamps (ESL)
  25. Lead oxide in glass used for bonding front and rear substrates of flat fluorescent lamps used for Liquid Crystal Displays (LCD)
  26. Lead and cadmium in printing inks for the application of enamels on borosilicate glass
  27. Lead as impurity in RIG (rare earth iron garnet) Faraday rotators used for fibre optic communication systems until 31 Dec-09
  28. Lead in finishes of fine pitch components other than connectors with a pitch of 0.65 mm or less with NiFe lead frames and lead in finishes of fine pitch components other than connectors with a pitch of 0.65 mm or less with copper lead frames
  29. Lead in solders for the soldering to machined through hole discoidal and planar array ceramic multilayer capacitors
  30. Lead oxide in plasma display panels (PDP) and surface conduction electron emitter displays (SED) used in structural elements; notably in the front and rear glass dielectric layer, the bus electrode, the black stripe, the address electrode, the barrier ribs, the seal frit and frit ring as well as in print pastes
  31. Lead oxide in the glass envelope of Black Light Blue (BLB) lamps
  32. Lead alloys as solder for transducers used in high-powered (designated to operate for several hours at acoustic power levels of 125 dB SPL and above) loudspeakers
  33. Hexavalent chromium in corrosion preventive coatings of unpainted metal sheetings and fasteners used for corrosion protection and Electromagnetic Interference Shielding in equipment falling under category three of Directive 2002/96/EC (IT and telecommunications equipment). Exemption granted until 1 July 2007.
  34. Lead bound in crystal glass as defined in Annex I (Categories 1, 2, 3 and 4) of Council Directive 69/493/EEC (1)
  35. Cadmium alloys as electrical/mechanical solder joints to electrical conductors located directly on the voice coil in transducers used in high-powered loudspeakers with sound pressure levels of 100 dB (A) and more
  36. Lead in soldering materials in mercury free flat fluorescent lamps (which e.g. are used for liquid crystal displays, design or industrial lighting)
  37. Lead oxide in seal frit used for making window assemblies for Argon and Krypton laser tubes
  38. Lead in solders for the soldering of thin copper wires of 100 μm diameter and less in power transformers
  39. Lead in cermet-based trimmer potentiometer elements
  40. Cadmium in photoresistors for optocouplers applied in professional audio equipment until 31 December 2009
  41. Mercury used as a cathode sputtering inhibitor in DC plasma displays with a content up to 30 mg per display until 1 July 2010
  42. Lead in the plating layer of high voltage diodes on the basis of a zinc borate glass body
  43. Cadmium and cadmium oxide in thick film pastes used on aluminum bonded beryllium oxide
  44. Cadmium in colour-converting II-VI LEDs (< 10 μg Cd per mm 2 of light-emitting area) for use in solid state illumination or display systems until 1 July 2014

Again:  as of March 2010.

For more information on RoHS:
For more information on WEEE:

* The second three of six substances of very restricted use under RoHS are:

  1. Hexavalent chromium (Cr6+)
  2. Polybrominated biphenyls (PBB)
  3. Polybrominated diphenyl ether (PBDE)