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ELC Guide to the

Restrictions of the
use of certain

Aura Light


Leuci S.p.A.

GE Lighting



Philips Lighting


RoHS Article 4(1)

Member States shall ensure that from 1st July 2006, new EEE
put on the market does not contain lead, mercury,

 Exemptions from the requirements of Art 4(1) are as follows:

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Exemptions on the use of

 Mercury - in CFLs not exceeding 5mg per lamp.
 Mercury - in Straight FLs for general purpose not exceeding

(per lamp):



Triphosphate [Triband phoshor] (normal lifetime)


Triphosphate [Triband phoshor] (long lifetime)


 Mercury - in Straight FLs for special purposes

(see slide 7)

 Mercury - in other lamps not specifically mentioned in the

RoHS annex

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(see slide 8)

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Exemptions on the use of


Fluorescent lamps with high colour rendering index

(Ra>90) with as major constituent halophosphate: limit 10
mg. Non-halophosphate containing lamps (Ra>90): same
as triphosphor lamps
Fluorescent lamps with external sleeve or coating (e.g.
fragment retention, coloured etc): same as straight FL for
general purpose

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Exemptions on the
use of Lead
 Lead in glass of Electronic components.

ELC definition is that starters & glow switches are electronic components.
Therefore starters and glow switches are exempt from restrictions on the
use of lead.

 Lead in glass of Fluorescent tubes

The original proposal for the exemption was that lead containing glass is
needed for exhaust tubes & flares of fluorescent lamps. Therefore this
exemption should only apply to these parts. The ELC will work towards a
redefinition of the wording in the directive to reflect this understanding.

 Lead in high melting temperature type solders.

These solders are needed for example for high intensity discharge (HID),
incandescent lamps for high temperature environments and high wattage
incandescent/halogen to provide for safe electrical contact and safety at
end of life.

 Lead as alloying element in steel containing up to 0.35% lead by weight, in

aluminum up to 0.4% lead by weight and as a copper alloy containing up to 4%

lead by weight (this pertains to a.o. lamp caps).

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ELC definition of lamps for

general purpose use
 Lamps for general lighting service are defined as:

Those products for general use in private & commercial

application areas.

 They generally possess the following


General Lighting sources provide a level of visible light in the

range 400 to 800 nm.

They are classified by the Energy Label.

They are highly standardised and interchangeable.

They are universally available.

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ELC definition of lamps for

special purpose use
 Lamps for Special purposes are needed where

other, specific characteristics are prescribed.

 They generally have the following characteristics:

They are not marketed or commercialised primarily for the

production of visible light .
They are marketed however:

Where the non-visible radiation has highest importance.

Where different looking lamp designs are relevant for use.

Where different applications require specific lamps.

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Mercury in Straight Fluorescent

Lamps for Special Purposes
(including diameters from 16mm up to 38 mm.)

 Fluorescent lamps for special purposes include for instance:

Black light lamps

Disinfection lamps

Medical/Therapy lamps

Food lighting applications, bakeries etc

Pet care lamps i.e. aquaria lamps

Lamps designed for UV emission like sun tanning lamps

Lamps with special components like integrated reflectors, external protective sleeve
or with external ignition strip
Lamps with special ignition features for example those designed for low

Long length lamps (length i.e. 8/2400mm)

Amalgam lamps

Cold Cathode Fluorescent Lamps

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Mercury in other lamps

(not specifically mentioned in the annex)

High Intensity Discharge (HID)

Circular lamps

U Bend lamps

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Other ELC definitions

Lead in lamp marking The mark is part of the lamp glass and is

therefore defined as a homogeneous material below the maximum

concentration limit of 0.1% by weight.
 Put on the market The ELC supports the text defined in the

European Commission Frequently Asked Questions on Dir RoHS

2002/95/EC and WEEE 2002/96/EC.
 The words put on the market in Article 10(3) of the WEEE directive

and Art 4(1) of the RoHS directive refer to the initial action of
making a product available for the first time on the community
market. This takes place when the product is transferred (e.g.
physical handover or transfer of ownership) from the producer to a
distributor or final consumer or user in the community market.
 For further information see link

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Other ELC definitions (cont)

 Spare parts issue - in general, lamps for

replacement in existing installation cannot be

considered as spare parts.

 The ELC definition of "spare parts is as follows:

Lamp is no longer commercially available, but can be listed

in separate spare part catalogue;
Equipment is produced before 1 July 2006.

 Return shipments - Products put on the market

before July 1st 2006, as described in Put on the

market see previous slide cannot be returned as
Non-RoHS compliant products!

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Lamps put on the market by OEM's

 A lamp is an 'electrical and electronic equipment'

in the sense of the Directive, therefore:

Any lamp supplied to an OEM prior to 1 July 2006, is put on

the market (and thus RoHS compliant).

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Put on the market for

Private Label
 A private label owner is also considered a producer (art. 3 of

Directive) and has an independent obligation under the RoHS

Directive to sell compliant products after 1 July 2006.
 Private label owners have an independent obligation to supply

compliant products as of 1 July 2006 onwards.

 The products that are on the shelves of the private label

owners on 1 July 2006 are compliant with the RoHS Directive

since they have been put on the market prior to 1 July by ELC
member companies.
 There is no need to treat products carrying a private label,

more severely than similar products without private label.

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Additional exemptions
approved by TAC
 High Intensity Discharge (HID) lamps for professional U.V.

applications, containing lead halide as radiant agent.

Lead is essential for creating the proper lamp emission

spectrum and lamp efficacy.

 Discharge lamps for special purposes containing lead as

activator in the fluorescent powder (1% lead by weight or


Lead is essential for creating the proper lamp emission

spectrum and lamp efficacy.

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Additional exemptions
approved by TAC (cont)
 Discharge lamps for special purposes which use lead in the

glass envelope.

This type of glass is required for transmission of appropriate


 Discharge lamps containing lead in the form of an amalgam.

Amalgam in some lamps is necessary to create smaller

lamps used as substitute of the less energy efficient
incandescent lamps, mainly in high power applications.

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Additional exemptions
requested by ELC (cont)
 Use of lead in solder and lead in glass solder for mercury free

flat-panel discharge lamps.

Solder with a concentration of 70 % lead is necessary to create a

safe electrical contact on the plane glass surface.
Lead containing glass solder is necessary to assembly the flatpanel glass envelope.

 Linear incandescent lamps with silicate coated tube.

Lead is essential for creating a proper bonding between glass and

silicate powder

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Frequently Asked Questions

 Are circular fluorescent lamps classified as other fluorescent

lamps included in Section 4 of the RoHS Annex?

Yes this is correct. They are classified under item 4 of the

RoHS annex.
This means that there are no restrictions regarding

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 Does the enclosed mercury amount of high-wattage straight

fluorescent lamps which exceed 80W satisfy the following




[Triband phoshor]


[Triband phoshor]


(normal lifetime)


(long lifetime)


The restrictions for mercury in straight fluorescent lamps

are independent of the wattage values.

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 How many hours are specifically designated for normal

lifetime and long lifetime, respectively of general-purpose

straight fluorescent lamps? Are they defined?

There is no official definition of normal & long lifetime in

the RoHS directive.
The ELC definition of long lifetime is as follows:

Where installed luminous flux (survival x maintenance) is higher than

80% at 25,000 hours with electronic ballast.

This is the long life definition for general purpose straight fluorescent

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 Does the total mercury content within high-wattage compact

fluorescent lamps which exceed 60W, also satisfy the

standard of 5 mg or lower?

The restriction for mercury in compact fluorescent lamps is

independent from the wattage values.

 Is the limit value of total mercury content defined as average

or maximum value?

Not defined.
The common practice is to use the average value. (Refer
Method to test mercury content given as appendix to
Commission Decision C(1999) 2439) which is an appendix
to 1999/568/EC.

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 Can starters for fluorescent lamps be regarded as electronic


Starters are electronic components of luminaires. Starters

and compact fluorescent lamps may contain a glow switch,
which is also an electronic component.

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 Is lead contained in the glass of lamps other than fluorescent,

such as incandescent, excluded from the application?

No, it is not. The RoHS directive applies to all lamps, including

incandescent lamps, hence the application of lead is forbidden.

 For starters for fluorescent lamps in which radioactive

substance is enclosed, can lead glass be used?

Since starters for fluorescent lamps are considered electronic

components they do not fall under the RoHS directive.
Starters and compact fluorescent lamps may contain a glow
switch as an electronic component. Lead in glass of electronic
components is excluded from the requirements of RoHS directive.
Therefore, lead glass can be used for glow switches.

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 Is lead contained in the mercury alloy (amalgam) used for

compact fluorescent lamps, etc. excluded from the


It is part of the ELC exemption request. See slides 13 to


 We think that lead of black-light phosphor and lead iodide for

metal halide lamps should be exempted from the application

as special use. Do you agree?

Yes, they form part of the revised exemption list as

proposed by the ELC. See slides 13 to 15.

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 What does the last item light bulbs in RoHS Annex Section 10 mean?

We acknowledge the fact that there appears to be some confusion between the
definition of light bulbs in the Waste Electrical and Electronic Equipment
(2002/96/EC) & Restriction of the Use of Hazardous Substances (2002/95/EC)
Directives, and the definition of light bulbs in the Eco Label Directive
(1999/568/EC) dated 27 July 1999.

The Eco Label wording refers to the term light bulbs as a generic term for all lamps. We
have suggested to the authorities that this should be referred to as 'light sources' in the Eco
Label Directive.
The WEEE Directive Annex 1b, point 5 excludes filament bulbs and the RoHS Directive
exemption list mentions light bulbs.

We suggest therefore that the terms filament bulbs and light bulbs should as a rule
be replaced by incandescent or filament lamps, in line with the intention of both
the WEEE and RoHS directives.
The technically and scientifically accepted term incandescent or filament lamps,
refers to two standardised lamp families:

Tungsten filaments lamps for domestic or similar general lighting purposes (IEC 60064).

Tungsten halogen lamps (non-vehicle) (IEC 60357).

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