Where else would EU Exemptions need to be disclosed for China RoHS?
There are many EU RoHS compliant components where lead is found in concentrations greater than 1000ppm. There is an exemption for lead in high melting type solders containing >85% lead, and for lead as an alloying element in steel to 0.35%, aluminum to 0.4% and copper alloys (including brass) to 4%. High melting type solders are found in the internals of many ICs, and if the IC is >4mm3 then the 1000 ppm applies at homogeneous level (EIP-A). The exemption for lead as an alloying element is derived from a free machining alloy spec. Any steel, aluminum, copper or brass part that has been machined is likely to contain lead in this form. Mercury can be in an EU compliant product in the back lights of LCD displays. Cadmium could be in switch contacts as there is an EU exemption for cadmium in switches. All of these will require an “X” in the box of the China RoHS Declaration Table for sub-assemblies containing these parts. If a product is EU RoHS compliant for Hexavalent Chromium, then the
