Lead is a material with special properties that continues to play an important role in industry. On the other hand, lead is a toxic heavy metal that should be minimized in the environment. Well-known OEMs are therefore already demanding and successfully using lead-free alternatives. The reasons for this are the increasing costs and risks associated with the use of lead. These additional effort is reflected in various regulations and directives worldwide:

RoHS (Restriction of Hazardous Substances)

The EU RoHS 2011/65/EU Directive aims to restrict the use of certain hazardous substances in electrical and electronic equipment. This is intended to minimize the release of these substances into the environment. Lead, as a substance subject to restrictions under Article 4(1) of the RoHS Directive, has a defined maximum allowable concentration of 0.1 % by weight in homogeneous materials.

Exemption 6c of Annex III allows "copper alloys containing up to 4% lead by mass." This exemption actually expires on July 21, 2021. As the responsible EU Commission has not yet announced a decision on a possible extension, the exemption remains valid until further notice. Details and the current status of the exemption are summarized in the following FAQs.

Note: All Powerelements from Würth Elektronik ICS are RoHS compliant. The original Powerelements are RoHS compliant according to the exemption Annex III, 6c. The lead-free LF Powerelements are RoHS compliant without exemption and therefore a future-proof solution.

ELV (End of Life Vehicles) Directive

The aim of the "End of Life Vehicles Directive" is to ensure that the materials and components of vehicles placed on the market are as environmentally friendly as possible and do not contain, for example, lead, mercury, cadmium or hexavalent chromium. For lead, a limit of up to 0.1 % by weight applies. Exemption 3 allows copper alloys containing up to 4% lead.

In the Official Journal of the European Union of March 10, 2023 on the "Amendment of Directive 2000/53/EC on end-of-life vehicles" announced a review of the exemption in 2025.

REACH (Registration, Evaluation, Authorization and Restriction of Chemicals)

REACH is a European Union regulation (EC No. 1907/2006) aimed at protecting human health and the environment from potential risks posed by chemicals. In 2018, lead was added to the Candidate List of Substances of Very High Concern (SVHC). According to Article 33 of the REACH Regulation, this results in an information obligation along the supply chain. If semi-finished or other products have been manufactured from copper alloys containing more than 0.1% lead, this must be indicated on delivery. The usability and applicability of products with copper alloys containing lead remains unaffected by the inclusion in the candidate list until further notice.

Note: Würth Elektronik ICS will indicate the lead content of >0.1 % fon the delivery documents for the non-lead-free Original Powerelements. 

RoHS exemption 6c was due to expired on July 21, 2021 for equipment categories 1-7 and 10, and partially for categories 8 and 9. However, some applications for an extension of the exemption were submitted in time. For this reason, exemption 6c will remain valid until the EU Commission has decided on these applications.

The Öko-Institut e.V. is currently examining the necessity and scope of an extension of the exemption. The Öko-Institut's report is an important scientific basis for the decision of the EU Commission. The EU Commission has not made a decision yet. 

This results in different scenarios thus arise for the expiry of exemption 6c of the RoHS Directive. Based on a typical project sequence in the electronics industry with a development time of three years and a product life cycle of seven years, the following two scenarios can be considered as examples.

Scenario 1: Three years exemption extension 

For equipment categories 1 through 7 and 10, the exemption may be extended for a maximum of five years. For equipment categories 8 and 9 for a maximum of seven years. However, the EU Commission can also set a shorter period. An extension for a further three years is conceivable and would then apply from the expiry date. Thus, the end date of the exemption extension would already be July 21, 2024, after which a so-called sunset phase would begin, a transition period that can last 12 to 18 months and is determined by the EU Commission. Taking into account the development and product life cycles, an immediate switch to lead-free alternatives is therefore recommended.

Scenario 2: Five years exemption extension 

If the exemption is extended for another 5 years, the expiration date of the exemption would be July 21, 2026, meaning that the sunset period would end in the middle of the product life cycle and leaded components would no longer be allowed to be sold. This would mean that products already developed would have to be re-qualified.

Based on current trends, our experts believe it is unlikely that  the sunset period will be extended beyond five years, and therefore recommend that the transition to lead-free alternatives should be considered now. New developments should always be based on lead-free components.

Let us advise you nowand stay future-proof!