RoHS exemptions for lead: when tin-lead alloys are still permitted
Since 2006 the RoHS Directive has made lead-free alloys the standard in European electronics. Tin-lead alloys have not disappeared, however: they remain permitted for products outside the scope of the directive and for uses covered by exemptions. This guide explains how to find your way. It does not replace checking the legislation in force, which must be done for each product.
Dickmann Srl · updated
What RoHS restricts
Directive 2011/65/EU (RoHS) restricts certain substances in electrical and electronic equipment. For lead, the limit is 0.1 % by weight in each homogeneous material: a tin-lead solder alloy exceeds the limit, so in equipment subject to RoHS it can only be used if an exemption allows it.
The alternatives for electronics are lead-free alloys: SAC305, SAC0307, Sn99.3Cu0.7 and 99SnCuNiGe.
The three situations in which lead is still permitted
| Situation | Examples | What to check |
|---|---|---|
| Products that are not electrical and electronic equipment | Sheet-metal work, zinc coffin liners, stained glass, mechanical repairs | That the product is genuinely out of scope, and the other applicable regulations |
| Equipment excluded from the scope of the directive | Large-scale stationary industrial tools, large-scale fixed installations, means of transport, military equipment | The definitions in Article 2 of the directive |
| Uses covered by an exemption | Entries in Annex III (all categories) and Annex IV (medical devices and monitoring and control instruments) | The current wording of the entry, its scope and its expiry date |
Exemptions have a limited duration and are periodically renewed, amended or revoked by delegated acts of the European Commission: always check the version in force.
Exemptions: how to find your way
Annex III lists the exemptions valid for all categories of equipment; among them is the one for lead in high-melting-temperature solders containing 85 % or more lead by weight. Annex IV contains specific exemptions for medical devices and for monitoring and control instruments, categories that came under RoHS later than the others.
For each entry, three things matter: the exact scope (component, material, type of equipment), the expiry date and any conditions. An exemption for a component does not cover the soldering of the entire board, and an expired exemption does not apply to new products placed on the market.
Spare parts, repairs and other regulations
The directive lays down specific rules for cables and spare parts intended for the repair of equipment placed on the market before the limits came into force: here too, the wording of the applicable article must be checked.
Besides RoHS there are other regulations on lead. Lead is on the REACH Candidate List: anyone placing on the market articles containing more than 0.1 % of it has communication obligations. For vehicles the ELV Directive applies, with its own exemptions; batteries follow the EU Batteries Regulation. For lead-acid batteries, see our battery grade alloys.
Dickmann tin-lead alloys
For uses where lead is permitted, Dickmann produces tin-lead alloys as 50/50 solder sticks, bars (63Sn37Pb, 60Sn40Pb, 63Sn35Pb2Ag), solid wire and flux-cored wires (for example 63Sn37Pb and 60Sn39PbCu1). With every delivery we send the safety data sheet and declarations of conformity.