Understanding Exemptions
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List
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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:
Exemptions applied to Lead in Metal Alloys
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)”
Exemptions applied to Lead in electronic components (resistors and
capacitors)
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 |
Exemptions applied to Lead in solder
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:
MBG only Exemptions
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)”