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List of all exemptions, including Chinese translations
The MBG W18 Specification provides exemptions for all Controlled substances, and are categorized by RoHS Substance, W18 General (W18-5) and W18 Surface Substance. As part of the new process, exemptions are populated by the Supplier. Up to three exemptions can be provided for a Substance
RoHS - applied whenever a RoHS substance category exceeds the RoHS threshold
MBG W18-5 - applied whenever a substance category exceeds the W18-5 threshold. There are overlapping substance categories between the RoHS and W18-5 categories, and the W18-5 is always lower
W18-Surface - applied whenever a W18-Surface substance category exceeds the W18-Surface threshold .Surface materials are those which are intended to come into direct and prolonged contact with the skin
There are 91 different exemptions in the Motorola IPC Creator, all of which are referenced in the W18. There include both EU RoHS Exemptions and W18 Specific Exemptions, which are based on different reasoning:
Time until implementation
No better alternative is available in the industry
Some for specific businesses or use
Hazardous substance is not damaging in this certain use
Exemptions must be provided if a W18 compliance threshold is exceeded. This may also require multiple exemptions to be applied to one substance category has overlapping restrictions in different specifications (ex: RoHS and W18)
Please refer to W18 Exemptions listed in the W18 and the guidance document posted at: www.motorola.com/us/cr-sp/suppliers-responsibility-materials-disclosure.html#suppliers-responsibility-materials-disclosure-w18-reporting
Below we will discuss the most frequently applied exemptions:
Lead is often used as an alloying element to obtain specific properties of a metal alloy
This exemption applies to the use of lead in:
steel up to 0.35% by weight,
aluminum up to 0.4% by weight
copper alloys up to 4% by weight
In the context of this exemption, ‘percentage by weight’ has to be interpreted as ‘the percentage of lead per homogeneous material per discreet part’
For example, if the steel housing of a computer consists of two separate parts, each part is considered separately, and can contain up to 0.35% lead by weight for their respective homogeneous materials
These are examples of appropriate exemptions to apply:
Lead in steel up to 0.35% by weight
RoHS exemption - 6(a) – “Lead as an alloying element in steel containing up to 0.35% lead by weight”
W18-5 - 518 – “Lead NOT in cable jackets or packaging; covered by RoHS”
W18 Surface - 538 – “Part contains Lead but will not have prolonged contact with skin (i.e. surface mount parts)”
Aluminum up to 0.4% by weight
RoHS exemption - 6(b) – “Lead as an alloying element in aluminum containing up to 0.4% lead by weight”
W18-5 - 518 – “Lead NOT in cable jackets or packaging; covered by RoHS”
W18 Surface - 538 – “Part contains Lead but will not have prolonged contact with skin (i.e. surface mount parts)”
Copper alloys up to 4% by weight
RoHS exemption - 6(c) – “Lead as an alloying element in copper containing up to 4% lead by weight”
W18-5 - 518 – “Lead NOT in cable jackets or packaging; covered by RoHS”
W18 Surface - 538 – “Part contains Lead but will not have prolonged contact with skin (i.e. surface mount parts)”
Ceramic and glass materials are used in a variety of electronic devices including capacitors and resistors.
Some of these ceramic and glass materials contain lead, for example lead zirconate titanate and lead magnesium niobate and lead oxide.
The specific chemical composition and manufacturing process of these materials determine their electrical parameters, such as dielectric constant and the dissipation that is essential for the functioning of the component in which they are used.
Hence, lead used in the ceramic parts of electronic components in electrical and electronic equipment is exempt from these RoHS.
In the context of this exemption, it is critical to note that lead must be part of a homogeneous ceramic substance within an electronic part and NOT part of the metal matrix which serves as a termination to the part
These are examples of appropriate exemptions to apply:
Lead in the glass layer of a resistor
RoHS exemption - 7(c)-I – “Electrical and electronic components containing lead in a glass or ceramic other than dielectric ceramic in capacitors, e.g. piezoelectronic devices, or in a glass or ceramic matrix compound”
W18-5 - 518 – “Lead NOT in cable jackets or packaging; covered by RoHS”
W18 Surface - 538 – “Part contains Lead but will not have prolonged contact with skin (i.e. surface mount parts)”
Lead in the ceramic dielectric of a high voltage capacitor
RoHS exemption - 7(c)-II – “Lead in dielectric ceramic in capacitors for a rated voltage of 125 V AC or 250 V DC or higher”
W18-5 - 518 – “Lead NOT in cable jackets or packaging; covered by RoHS”
W18 Surface - 538 – “Part contains Lead but will not have prolonged contact with skin (i.e. surface mount parts)”
Lead in the ceramic dielectric of a low voltage capacitor
RoHS exemption - 7(c)-III – “Lead in dielectric ceramic in capacitors for a rated voltage of less than 125 V AC or 250 V DC”
W18-5 - 518 – “Lead NOT in cable jackets or packaging; covered by RoHS”
W18 Surface - 538 – “Part contains Lead but will
not have prolonged contact with skin (i.e. surface mount parts)”
Exemption 7(c)-III expired 1/1/2013. We do not recommended using low voltage capacitors containing lead in ceramic dielectric for new parts and products |
Lead is used in a a variety of solders to produce alloys with specific melting temperatures and strength.
As there are no alternatives to lead in key applications of low and high melting temperature solders, they are exempted by RoHS in specific solder formulations and applications.
The presence of Lead must be confirmed to be part of a solder alloy and the weight % of the Lead must be understood to apply an appropriate exemption. (e.g. Pb 88%, Sn 12; or Pb 86% Sn 10%, Sb 4%)
These are examples of appropriate exemptions to apply:
Lead in Solder (less than 85%)
RoHS exemption - 7(b) – “Lead in solders for servers, storage and storage array systems, network infrastructure equipment for switching, signaling, transmission as well as network management for telecommunications”
W18-5- 518 – “Lead NOT in cable jackets or packaging; covered by RoHS”
W18 Surface - 538 – “Part contains Lead but will not have prolonged contact with skin (i.e. surface mount parts)”
Lead in Solder (greater than 85%)
RoHS exemption – 7(a) – “Lead in high melting temperature type solders (i.e. lead based solder alloys containing 85% by weight or more lead)”
W18-5 - 518 – “Lead NOT in cable jackets or packaging; covered by RoHS”
W18 Surface - 538 – “Part contains Lead but will not have prolonged contact with skin (i.e. surface mount parts)”
As previously discussed, some substances are only controlled by MBG, or MBG controls them at a lower threshold. For these substances, we have MBG specific exemptions. Some examples are:
Nickel – that does not have prolonged contact with skin
W18-5 Exemption - 501 – “Part contains Nickel, but will not have prolonged contact with skin”
Azo Dyes – not used in leather or textiles (> 30 PPM)
W18-5 Exemption - 517 – “Usage of azodyes is NOT in leather and/or textiles per EU Directive 2002/61/EC”
Lead (> 70 PPM, < 1000 PPM) – where above MBG threshold, but below the RoHS threshold
W18-5 Exemption - 518 – “Lead NOT in cable jackets or packaging; covered by RoHS”
W18 Surface Exemption - 538 – “Part contains Lead but will not have prolonged contact with skin (i.e. surface mount parts)”
Lead in a cable jacket (< 300 PPM)
W18-5 Exemption - 513 – “Lead in Cable Jackets only, up to 300 ppm per California Prop 65”
W18 Surface Exemption - 538 – “Part contains Lead but will not have prolonged contact with skin (i.e. surface mount parts)”