I need help with an interpretation of exemption Number 7 in the ROHS annex
regarding servers.

The exemption reads:
"- lead in solders for servers, storage and storage array systems (exemption
granted until 2010)"

The annex does not just say "lead" -- it says "lead in solders".  Therefore,
there is an opinion that only lead used in solder is considered exempt
(until 2010).  Lead used elsewhere (such as in component finishes) is not
exempt.

I have read a DTI guidance document - July 2004 that suggests that solder is
defined as "alloys used to create metallurgical bonds between two or more
metal surfaces to achieve an electrical or physical connection."  The same
document also states that their interpretation is that the exemption applies
to the whole of the finished device to include components (where
metallurgical bonds are created).  With this in mind, we have now formed a
different opinion that component finishes can fall within the exemption.

Would anyone on this forum like to offer an opinion on which interpretation
is compliant with the exemption?

Thanks for your consideration of my dilemma,

Tracey C


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