Finding surface mount resistors that meet legal requirements - Lead free UK/EU - Page 1
Forum section: electronics / projects

author: DaveBex
author_rank: Newbie
timestamp: August 04, 2023, 10:47:25 pm
content: Hi,looking for input from other professional engineers - UK and EU - may apply to other locations as well but outside my understanding.I am having real difficulty in locating surface mount resistors in the UK/EU that comply with the RoHS, legislation.Expect you will all be saying that the distributers all sell surface mount resistors, that they and the manufactures say are RoHS compliant -- and that is true if it was before 21st July 2021.Almost all of the resistors are sold with RoHS and lead free on the data sheet - BUT if you look in to it a bit closer that is not exactly true, the correct description is they are lead free using the exemption 7(c)i in the RoHS legislation.Almost all of the data just says lead free and RoHS compliant - but once you push for a full compliance declaration the exemption is there.So it uses the exemption - that is no problem ? ... well it would be if the exemption (both EU and UK) had not expired for almost all uses as of 21st July 2021.It looks as if this is not well known - at first I was thinking I had read the legislation wrong - or just looking at the wrong parts - but it looks to be a problem that has been "overlooked" - talking to some of the largest UK/EU/Worldwide distributors when you ask about compliant parts - the first response is that they are - then when you push pointing out the exemption has expired they go very quiet and no more correspondence is entered in to.The head of the purchasing department at my employer has recently had a meeting with one of the largest distributers in the EU, and when the subject was brought up - they insisted the exemption would be extended.Considering the changes where put in place in 2018 after industry consultation the for most uses the exemption expired in 2021 and extension is not going to happen.There are a few truly lead free parts being sold but often only a limited range is stocked and often only one of two rolls are stocked compared to the 100+ for the parts with lead, and as a result at 2-4 times the price- some of the largest makers of resistors don't currently have lead free general purpose resistors.( Often the 0.1% 25ppm parts are lead free but the commodity 1% 100/200ppm parts are not)So my question what are other UK/EU manufactures or even ones shipping to UK/EU doing ?For the ones interested to delve deeper summery of the legislation below - have deleted some parts that may ID my employer or productsThe end date for the exemption was set in 2018 after a period of industry consultation ((EU) 2018/736 of 27 February 2018http://data.europa.eu/eli/dir_del/2018/736/oj)The exemption expired on 21st July 2021 for Categories 1 -7 and 10There is a second clause with the same date for Category 8 and 91. Large household appliances.2. Small household appliances.3. IT and telecommunications equipment.4. Consumer equipment.5. Lighting equipment.6. Electrical and electronic tools.7. Toys, leisure, and sports equipment.8. Medical devices.9. Monitoring and control instruments including industrial monitoring and control instruments.10. Automatic dispensers.11. Other EEE not covered by any of the categories above.The next data was this year – only last week or so - For category 8 in vitro diagnostic medical devices expires on 21 July 2023.That leaves the last date of 21st July 2024 for the final fall of category 9 ( Monitoring and control) and category 11.The full text of the directive ishttp://data.europa.eu/eli/dir/2011/65/2023-03-01has all the changes include – rather than having to check all the changes against the directive.The UK replacement post BREXIT is “The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012”https://www.legislation.gov.uk/uksi/2020/1647/schedule/2/madesee Table 1 No 21 same date is given.

author: Someone
author_rank: Super Contributor
timestamp: August 04, 2023, 11:23:32 pm
content: Perhaps you could link (or screen cap) such disclaimers/exemptions that the manufacturers are claiming?Reputable brand parts I've been using have 22/23 year data sheets claiming RoHS (+REACH) compliance without any sneaky *

author: DaveBex
author_rank: Newbie
timestamp: August 05, 2023, 12:38:45 am
content: Ok as a good example look at the CR1206-FX-1002ELF from bourns, a typical commodity part - 10K 1%, the data sheet ishttps://www.bourns.com/docs/product-datasheets/cr.pdfFrom that data sheet it looks to say its RoHS compliant -- but it is NOT !The first clue is in the data sheet there is a note linked to the RoHS compliant line of"RoHS Directive 2015/863, Mar 31, 2015 and Annex" .. the problem is that one is long out of date.Now look at the materials declarationhttps://www.bourns.com/docs/Product-MDS/cr1206_mds.pdfand you will find it has 0.22% of lead in it - that is no longer RoHS compliant.(There is the without exemption versionhttps://www.bourns.com/docs/product-datasheets/cr-pf.pdfbut finding the CR..PF series in distribution not easy - expensive and limited range. The CR1206-FX-1002EPF the lead free 10K 1% for example I cannot find in distribution at all.)CRCW020110K0FNED from Vishay Daledatahttps://www.vishay.com/docs/20052/crcw0201e3.pdfall looks nice saying Pb free etc --But look at the documenthttps://www.vishay.com/docs/99912/mat_cat_policy.pdfand you will see the logo for Pb free is only for lead free contacts -- there is still lead in the resistor element --have a material declaration but may be under NDA - so look athttps://www.vishay.com/en/product/20052/tab/quality/and the fact that the RoHS status is "Yes with exemptions" gives the game away.And this is a pattern repeated with almost all resistors that are on the market in volume - some have data that is publicly available like Bourns - but getting material data sheets for some needs an NDA - but it seams lead always makes an appearance.The own brand 1% 1206,0805 etc from all the larger EU distributers are the same.If you have examples can you link - have access to other data I can use to check most brands but most subject to NDA.

author: Tomorokoshi
author_rank: Super Contributor
timestamp: August 05, 2023, 01:41:49 am
content: How about these:https://www.digikey.com/en/products/filter/chip-resistor-surface-mount/52Select these categories:7C1 RoHS w/out Exemption (100% Pb-Free)7C1 RoHS w/out Exemption (100% Pb-Free), AEC-Q200And get these series:https://www.yageo.com/upload/media/product/productsearch/datasheet/rchip/PYu-RC_51_RoHS_P_5.pdfhttps://www.seielect.com/Catalog/SEI-RMEF.pdf

author: Someone
author_rank: Super Contributor
timestamp: August 05, 2023, 01:49:04 am
content: Seems like manufacturers are being pretty up front and honest about this.Quote from:https://www.koaglobal.com/product/library/resistor/trend?sc_lang=en

author: Someone
author_rank: Super Contributor
timestamp: August 05, 2023, 01:56:54 am
content: Quote from: Tomorokoshi on August 05, 2023, 01:41:49 amLooks like another set of manufacturer specific attributes, there are other parts (significantly higher in count) stocked by digikey that dont have that associated with them but are still "zero intentional use" etc and meeting RoHS without exemption.

author: Conrad Hoffman
author_rank: Super Contributor
timestamp: August 05, 2023, 03:09:30 am
content: Seems almost impossible to believe in this day and age. I wonder if something like this might be useful-https://koslow.com/products/lead-in-solder-kit-1553Prove it one way or another, regardless of claims.

author: Niklas
author_rank: Frequent Contributor
timestamp: August 05, 2023, 09:10:20 pm
content: The 7(c)-1 exemption for resistors is still valid as there is not yet a viable solution for mass production without lead in the glass passivation layer. Check the Excel sheet from March 2023, row 220.https://environment.ec.europa.eu/topics/waste-and-recycling/rohs-directive/implementation-rohs-directive_en

author: DaveBex
author_rank: Newbie
timestamp: August 07, 2023, 10:39:41 am
content: Hi Thank you Niklas for that information.That is interesting, having read all of the RoHS directive - had not found this extension - don't quite understand why the request for the continued existence of the exemption had not be made prior to 2018 when the current dates where set. (have found the requests from major resistor manufacturers that where at the time rejected)This now possibly puts me in a difficult situation, as the UK post BREXIT legislation does not look to have the same extensions, so may still need to make used of the lead free parts that are becoming available.Also have the problem that our largest customers are still requesting documentation to prove all resistors are lead free post June 2023, I note that the spread sheet says its a documentation tool only and does not have any legal standing.The documents that I understand to be legally in force still has the exemption expiring - need to go through all the documentation to verify the standing of the changes to the extension, and then see if I can convince our customers it is valid, and find if the UK legislation has the same variation in place.I am surprised that the distributors I have asked about the continued existence of only lead containing parts, have not sighted the same documentation .. more research needed !Thanks all for your help.

author: switchabl
author_rank: Frequent Contributor
timestamp: August 07, 2023, 03:59:35 pm
content: The legal basis is article 5 of the RoHS directive:QuoteSeveral companies have filed for a renewal of exemption 7(c)-1. A study was commissioned in 2021 which recommended that the exemption should be renewed, potentially in a somewhat narrower form (https://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_Pack_22/RoHS_Pack-22_final_report_amended_February_2022.pdf). Since there is still no final decision, even though the exemption technically expired 21 July 2021, it is still valid for at least another 12 months, and likely longer. If this sounds messy and confusing to you, that's because it is.I would assume that since the applications for renewal were filed before the end of the transition period that the sameshouldsomehow apply in the UK (well, GB more like, I believe the EU RoHS directive still applies verbatim in NI). But then, who knows what applies in the UK these days. UK government has also announced that they intend to recognize CE indefinitely for "most goods" which might render the point moot. But so far RoHS (and ecodesign) are conspicuously missing from their list (https://www.gov.uk/government/news/uk-government-announces-extension-of-ce-mark-recognition-for-businesses).