Slightly OT-Restriction of Hazardous Substances Directive

We have a part that is going to be exported. Part of the assembly is 12L14 stock which is 0.15 to 0.35% lead. If I understand the restrictions stated below correctly then the part can't be made with this material. Have any of you come up against the ROHS issue in manufacturing and how did you deal with it? Thanks.

"The maximum permitted concentrations in non-exempt products are 0.1% or 1000 ppm (except for cadmium, which is limited to 0.01% or 100 ppm) by weight. The restrictions are on each homogeneous material in the product, which means that the limits do not apply to the weight of the finished product, or even to a component, but to any single substance that could (theoretically) be separated mechanically—for example, the sheath on a cable or the tinning on a component lead.

As an example, a radio is composed of a case, screws, washers, a circuit board, speakers, etc. The screws, washers, and case may each be made of homogenous materials, but the other components comprise multiple sub-components of many different types of material. For instance, a circuit board is composed of a bare PCB, ICs, resistors, capacitors, switches, etc. A switch is composed of a case, a lever, a spring, contacts, pins, etc., each of which may be made of different materials. A contact might be composed of a copper strip with a surface coating. A speaker is composed of a permanent magnet, copper wire, paper, etc.

Everything that can be identified as a homogeneous material must meet the limit. So if it turns out that the case was made of plastic with 2,300 ppm (0.23%) PBB used as a flame retardant, then the entire radio would fail the requirements of the directive."

Did not understand the gobblygook in the directive. Spending time trying to understand would be depressing so I am not even going to try. What about substituting material, C1117 machines fairly easily. I think calcium has been substituted for lead in the past, maybe selenium or terulium also. I have not had the need so I am not sure what is out there.

Thanks Fred. The explanation I included was supposed to be "understanding ROHS for dummies". I got about as much out of it as you did. I was curious if anyone had actually been involved in this and might have some idea of what this all means. Yes there is a good possibility to substitute materials. I am concerned about other projects that have been completed that contain leaded steel and cadmium plating. Trying not to get burned after the fact.

Talk to your steel supplier. They should be familiar with ROHS and REACH requirements.

They should have a list and a certification of the compatibility of the materials.
Locally, Jorgensen was able to give me a certification for the materials I was using.

It depends what the part is going to be used in (end product). The RoHS directive only applies to electrical and electronic devices. The original ROHS directive referred to the WEEE directive for scope of products covered. I believe the new "recast" RoHS directive now includes the scope of products right in it. Always check the scope to see if you're in or out before reading further...

If it does go in an electrical product, you can't use that material since it's over 0.1%. There are some exeptions in the directive allowing use of lead in special cases, but they're pretty specific.

Get a material declaration from your supplier, better yet is a material analysis/composition report.