Gordon

The Marketing and Use of Dangerous Substances Directive (91/338/EEC as
amended) bans the use of Cadmium in certain sectors but gives an across the
board Ok to the use of Cadmium plating in electrical contacts.

The RoHS directive exempts Cadmium plating unless it's banned under the
Dangerous Substances Directive.  As cadmium plating on electrical contacts
is not banned under that, it's not banned under RoHS.  I believe that what
RoHS is trying to prevent is the use of Cadmium in pigments.

With regard to batteries, which were also mentioned on the forum, para 10 of
the directive pre-amble says that the directive shall apply without
prejudice to .....Council Directive 91/157/EEC on batteries and
accumulators...

Consumables also do not fall within the scope of the directives.

UK views this as meaning that batteries do not fall within the scope of
RoHS.

The WEEE directive does however require their removal from separately
collected WEEE.

UK are planning on publishing draft regulations and non-statutory guidance
this month.  Watch this space.

Regards

Nick

From:  Nick Jolly, Dept. of Trade & Industry
           Electronics Unit
E-mail: [log in to unmask]
Tel:     +44 (0)20 7215 1331
Fax:    +44 (0)20 7215 1966
Mobile: 0787 640 7444
Snail:   Bay 254
           151 Buckingham Palace Road
           London SW1W 9SS


-----Original Message-----
From: Davy, Gordon [mailto:[log in to unmask]]
Sent: 16 June 2004 19:42
To: [log in to unmask]
Subject: Re: [LF] RoHS Directive


Chuck Dolci writes, "I received an opinion of counsel in Brussels that says
batteries are not covered under RoHS, since they are covered under their own
Directive (91/157/EEC)." I hope that the opinion that a material use covered
by another directive is not covered by RoHS is correct. It would be nice is
the directive actually said that.

Here's another situation. RoHS is aimed at other substances in addition to
lead, including cadmium. Certain uses of cadmium are covered (as item 24) by
the Dangerous Substances Directive, 76/769/EEC (as amended),
http://europa.eu.int/comm/enterprise/chemicals/legislation/markrestr/consoli
d_1976L0769_en.pdf
<http://europa.eu.int/comm/enterprise/chemicals/legislation/markrestr/consol
id_1976L0769_en.pdf> . The RoHS Annex (which lists exemptions from the "does
not contain" requirement) explicitly permits (item 8) cadmium plating, as
long as it is not prohibited by the other directive. That directive forbids
cadmium plating in equipment and machinery for production of certain kinds
of products, so one can conclude that under RoHS use of cadmium plating in
other applications is legal. The Dangerous Substances Directive also refers
to other uses of cadmium, but does not refer to, and hence does
not restrict, cadmium in electrical contacts. Thus, because the Dangerous
Substances Directive, does not restict cadmium in electrical contacts, and
because the RoHS Annex does not list it as an exemption, it appears this use
will be forbidden.

I am told that cadmium is used with silver in electrical contacts used to
switch high currents to retard contact erosion, and that there is no
substitute that gives equal performance. Just think of the number of cases
of cadmium poisoning due to this use that will be prevented once RoHS goes
into effect.

Gordon Davy
Baltimore, MD
[log in to unmask]
410-993-7399


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