061129 RoHs

Aura Light BLV Leuci S.p.A. GE Lighting NARVA OSRAM GmbH Philips Lighting SLI

ELC Guide to the Directive

2002/95/EC on

Restrictions of the use of certain Hazardous Substances(RoHS)

ELC RoHS FAQ 060314

RoHS Article 4(1)

Member States shall ensure that from 1st July 2006, new EEE put on the market does not contain lead, mercury,

cadmium.....

Exemptions from the requirements of Art 4(1) are as follows:

ELC RoHS FAQ 060314

Exemptions on the use of Mercury

Mercury - in CFLs not exceeding 5mg per lamp.

Mercury - in Straight FLs for general purpose not exceeding (per lamp):

Halophosphate - 10mg

Triphosphate [Triband phoshor] (normal lifetime) - 5mg

Triphosphate [Triband phoshor] (long lifetime) - 8mg

Mercury - in Straight FLs for special purposes (see slide 7)

Mercury - in other lamps not specifically mentioned in the

RoHS annex (see slide 8)

ELC RoHS FAQ 060314

Mercury

Fluorescent lamps with high colour rendering index (Ra>90) with as major constituent halophosphate: limit 10 mg. Non-halophosphate containing lamps (Ra>90): same as triphosphor lamps

Fluorescent lamps with external sleeve or coating (e.g. fragment retention, coloured etc): same as straight FL for general purpose

Exemptions on the use of Mercury

ELC RoHS FAQ 060314

Exemptions on the use of Lead

Lead in glass of Electronic components.

ELC definition is that starters & glow switches are electronic components.

Therefore starters and glow switches are exempt from restrictions on the use of lead.

Lead in glass of Fluorescent tubes

The original proposal for the exemption was that lead containing glass is needed for exhaust tubes & flares of fluorescent lamps. Therefore this exemption should only apply to these parts. The ELC will work towards a redefinition of the wording in the directive to reflect this understanding.

Lead in high melting temperature type solders.

These solders are needed for example for high intensity discharge (HID), incandescent lamps for high temperature environments and high wattage incandescent/halogen to provide for safe electrical contact and safety at end of life.

Lead as alloying element in steel containing up to 0.35% lead by weight, in aluminum up to 0.4% lead by weight and as a copper alloy containing up to 4% lead by weight (this pertains to a.o. lamp caps).

ELC RoHS FAQ 060314

ELC definition of lamps for general purpose use

Lamps for general lighting service are defined as:

Those products for general use in private & commercial

application areas.

They generally possess the following characteristics:

General Lighting sources provide a level of visible light in therange 400 to 800 nm.

They are classified by the Energy Label.

They are highly standardised and interchangeable.

They are universally available.

ELC RoHS FAQ 060314

ELC definition of lamps for special purpose use

Lamps for Special purposes are needed where other, specific characteristics are prescribed.

They generally have the following characteristics:

They are not marketed or commercialised primarily for the production of visible light .

They are marketed however:

Where the non-visible radiation has highest importance.

Where different looking lamp designs are relevant for use.

Where different applications require specific lamps.

ELC RoHS FAQ 060314

Mercury in Straight Fluorescent Lamps for Special Purposes

(including diameters from 16mm up to 38 mm.)

Fluorescent lamps for special purposes include for instance:

Black light lamps

Disinfection lamps

Medical/Therapy lamps

Food lighting applications, bakeries etc

Pet care lamps i.e. aquaria lamps

Lamps designed for UV emission like sun tanning lamps

Lamps with special components like integrated reflectors, external protective sleeve or with external ignition strip

Lamps with special ignition features for example those designed for low temperatures

Long length lamps (length i.e. 8/2400mm)

Amalgam lamps

Cold Cathode Fluorescent Lamps

ELC RoHS FAQ 060314

Mercury in other lamps (not specifically mentioned in the annex)

High Intensity Discharge (HID)

Circular lamps

U Bend lamps

ELC RoHS FAQ 060314

Other ELC definitions

Lead in lamp marking The mark is part of the lamp glass and is therefore defined as a homogeneous material below the maximum concentration limit of 0.1% by weight.

Put on the market The ELC supports the text defined in the European Commission Frequently Asked Questions on Dir RoHS 2002/95/EC and WEEE 2002/96/EC.

The words put on the market in Article 10(3) of the WEEE directive and Art 4(1) of the RoHS directive refer to the initial action of making a product available for the first time on the community market. This takes place when the product is transferred (e.g. physical handover or transfer of ownership) from the producer to a distributor or final consumer or user in the community market.

For further information see link http://europa.eu.int/comm/environment/waste/pdf/faq_weee.pdf

ELC RoHS FAQ 060314

Other ELC definitions (cont)

Spare parts issue - in general, lamps for replacement in existing installation cannot be considered as spare parts.

The ELC definition of "spare parts is as follows:

Lamp is no longer commercially available, but can be listed in separate spare part catalogue;

Equipment is produced before 1 July 2006.

Return shipments - Products put on the market before July 1st 2006, as described in Put on the market see previous slide cannot be returned as Non-RoHS compliant products!

ELC RoHS FAQ 060314

Lamps put on the market by OEM's

A lamp is an 'electrical and electronic equipment' in the sense of the Directive, therefore:

Any lamp supplied to an OEM prior to 1 July 2006, is put on the market (and thus RoHS compliant).

ELC RoHS FAQ 060314

Put on the market for Private Label

A private label owner is also considered a producer (art. 3 of Directive) and has an independent obligation under the RoHS Directive to sell compliant products after 1 July 2006.

Private label owners have an independent obligation to supply compliant products as of 1 July 2006 onwards.

The products that are on the shelves of the private label owners on 1 July 2006 are compliant with the RoHS Directive since they have been put on the market prior to 1 July by ELC member companies.

There is no need to treat products carrying a private label, more severely than similar products without private label.

ELC RoHS FAQ 060314

Additional exemptions approved by TAC

High Intensity Discharge (HID) lamps for professional U.V. applications, containing lead halide as radiant agent.

Lead is essential for creating the proper lamp emission spectrum and lamp efficacy.

Discharge lamps for special purposes containing lead as activator in the fluorescent powder (1% lead by weight or less).

Lead is essential for creating the proper lamp emission spectrum and lamp efficacy.

ELC RoHS FAQ 060314

Additional exemptions approved by TAC (cont)

Discharge lamps for special purposes which use lead in the glass envelope.

This type of glass is required for transmission of appropriate radiation.

Discharge lamps containing lead in the form of an amalgam.

Amalgam in some lamps is necessary to create smaller lamps used as substitute of the less energy efficient incandescent lamps, mainly in high power applications.

ELC RoHS FAQ 060314

Additional exemptions requested by ELC (cont)

Use of lead in solder and lead in glass solder for mercury free flat-panel discharge lamps.

Solder with a concentration of 70 % lead is necessary to create a safe electrical contact on the plane glass surface.

Lead containing glass solder is necessary to assembly the flat-panel glass envelope.

Linear incandescent lamps with silicate coated tube.

Lead is essential for creating a proper bonding between glass and silicate powder

ELC RoHS FAQ 060314

Frequently Asked Questions (FAQs)

Are circular fluorescent lamps classified as other fluorescent lamps included in Section 4 of the RoHS Annex?

Yes this is correct. They are classified under item 4 of the RoHS annex.

This means that there are no restrictions regarding mercury.

ELC RoHS FAQ 060314

FAQs

Does the enclosed mercury amount of high-wattage straight fluorescent lamps which exceed 80W satisfy the following standard?

Halophosphate - 10mg

Triphosphate [Triband phoshor] (normal lifetime) - 5mg

Triphosphate [Triband phoshor] (long lifetime) - 8mg

The restrictions for mercury in straight fluorescent lamps are independent of the wattage values.

ELC RoHS FAQ 060314

FAQs

How many hours are specifically designated for normal lifetime and long lifetime, respectively of general-purpose straight fluorescent lamps? Are they defined?

There is no official definition of normal & long lifetime in the RoHS directive.

The ELC definition of long lifetime is as follows:

Where installed luminous flux (survival x maintenance) is higher than 80% at 25,000 hours with electronic ballast.

This is the long life definition for general purpose straight fluorescent lamps.

ELC RoHS FAQ 060314

FAQs

Does the total mercury content within high-wattage compact fluorescent lamps which exceed 60W, also satisfy the standard of 5 mg or lower?

The restriction for mercury in compact fluorescent lamps is independent from the wattage values.

Is the limit value of total mercury content defined as average or maximum value?

Not defined.

The common practice is to use the average value. (Refer Method to test mercury content given as appendix to Commission Decision C(1999) 2439) which is an appendix to 1999/568/EC.

ELC RoHS FAQ 060314

FAQs

Can starters for fluorescent lamps be regarded as electronic components?

Starters are electronic components of luminaires. Starters and compact fluorescent lamps may contain a glow switch, which is also an electronic component.

ELC RoHS FAQ 060314

FAQs

Is lead contained in the glass of lamps other than fluorescent, such as incandescent, excluded from the application?

No, it is not. The RoHS directive applies to all lamps, including incandescent lamps, hence the application of lead is forbidden.

For starters for fluorescent lamps in which radioactive substance is enclosed, can lead glass be used?

Since starters for fluorescent lamps are considered electronic components they do not fall under the RoHS directive.

Starters and compact fluorescent lamps may contain a glow switch as an electronic component. Lead in glass of electronic components is excluded from the requirements of RoHS directive. Therefore, lead glass can be used for glow switches.

ELC RoHS FAQ 060314

FAQs

Is lead contained in the mercury alloy (amalgam) used for compact fluorescent lamps, etc. excluded from the application?

It is part of the ELC exemption request. See slides 13 to 15.

We think that lead of black-light phosphor and lead iodide for metal halide lamps should be exempted from the application as special use. Do you agree?

Yes, they form part of the revised exemption list as proposed by the ELC. See slides 13 to 15.

ELC RoHS FAQ 060314

FAQs

What does the last item light bulbs in RoHS Annex Section 10 mean?

We acknowledge the fact that there appears to be some confusion between the definition of light bulbs in the Waste Electrical and Electronic Equipment (2002/96/EC) & Restriction of the Use of Hazardous Substances (2002/95/EC) Directives, and the definition of light bulbs in the Eco Label Directive (1999/568/EC) dated 27 July 1999.

The Eco Label wording refers to the term light bulbs as a generic term for all lamps. We have suggested to the authorities that this should be referred to as 'light sources' in the Eco Label Directive.

The WEEE Directive Annex 1b, point 5 excludes filament bulbs and the RoHS Directive exemption list mentions light bulbs.

We suggest therefore that the terms filament bulbs and light bulbs should as a rule be replaced by incandescent or filament lamps, in line with the intention of both the WEEE and RoHS directives.

The technically and scientifically accepted term incandescent or filament lamps, refers to two standardised lamp families:

Tungsten filaments lamps for domestic or similar general lighting purposes (IEC 60064).

Tungsten halogen lamps (non-vehicle) (IEC 60357).

ELC RoHS FAQ 060314

061129 RoHs

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Transcript of 061129 RoHs