Lead Forensics

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EU RoHS – Restriction of Hazardous Substances

EU RoHS – 2011/65/EU

The leading legislation for change, to consider the impact of discarded electronics on the environment; RoHS has arguably been the first and main driver for change in the industry. Member States of the EU have raised their own legislation to meet, if not exceed, these directives. Other countries and trading communities across the world are also passing laws which reflect the intent of the RoHS Directive.

The first RoHS Directive (2002/95/EC) has now been superseded by “RoHS 2” (2011/65/EU). The restricted substances covered by the latest version of the legislation are as follows:

Initial List (from 2006):

  • Lead (Pb)
  • Mercury (Hg)
  • Cadmium (Cd)
  • Hexavalent Chromium (Cr6)
  • Polybrominated Biphenyls (PBB)
  • Polybrominated Diphenyl Ethers (PBDE) including DecaBDE

Added substances (2015/863, published 31 March 2015):

  • Bis(2-ethylhexyl) phthalate (DEHP)
  • Butyl benzyl phthalate (BBP)
  • Dibutyl phthalate (DBP)
  • Diisobutyl phthalate (DIBP)

The maximum permitted concentrations in non-exempt products are 0.1% or 1000 ppm (except for Cadmium, which is limited to 0.01% or 100 ppm) by weight in any homogeneous material contained within an article.

Harwin and RoHS

Under this directive, Harwin’s products fall into three different circumstances.

  1. Hand tooling – none of the tooling supplied by Harwin is electrical or electronic, they are all mechanical non-powered devices. As such, they are not included within the scope of RoHS.
  2. RoHS-compatible products. Harwin products are not required to be compliant as complete items themselves – however, once they are incorporated in a piece of electrical or electronics equipment, they will be considered to be a collection of homogeneous materials and must therefore meet the material requirements of the legislation. Harwin declare products as RoHS compliant to aid customers in choosing the right products for a complete RoHS compliant build list.
  3. Non-RoHS products. Some of our customers fall within industries or applications that are still exempt. Harwin still maintain a small quantity of popular products with a tin/lead finish for these industries – however, these items are subject to continued demand and availability may vary.


Items that fall under (b) are labelled as “RoHS compliant” on the individual product page. To qualify as a RoHS compliant product, Harwin ensure the following two conditions are met:

  • The item must meet the restricted materials levels in all homogeneous parts of the product.
  • Any plastics used in an item designed as a solderable product must also use a plastic with a high melting point, typically greater than 290°C. This is because many RoHS compliant soldering processes run at a higher soldering temperature than Non-RoHS processes. Typically, RoHS compliant products from Harwin will be rated to a maximum recommended soldering temperature of 260°C for 10 seconds.

RoHS statements for Harwin products

Because Harwin supply products that are either not covered by RoHS, or are not suitable for RoHS, we are unable to supply a generic statement to cover all products.

To find a RoHS statement for a standard product, please use the search bar at the top of the page to find the product’s individual page. There are two links to the RoHS statement on the product page:

1) In the first box:


2) In Literature, click on the "Environmental Compliance" tab to reveal the list:


If you require a RoHS statement for a product not listed on our website (such as a custom manufactured product), please contact [email protected] for assistance.

Exemptions in EU RoHS

The only exemption present in any Harwin products is the 6(c) exemption:

  • Copper alloy containing up to 4% lead by weight

Both the product page and the RoHS statement for a Harwin product will declare if the 6(c) exemption has been utilised.

This exemption is required in Harwin products for all those items using turned brass. Free-machining brass is typically used for turning purposes – it is far easier to machine than brass without lead, and therefore is necessary for economic and toolwear reasons. The original date for this exemption to expire was 21st July 2016. In line with the Directive, applications for renewal of this exemption were filed by multiple companies within the required timescale.

There is a helpful detailed explanation of the original 2016 situation on the Copper and Brass Fabricators Council website (a non-profit trade association based in USA).

You can read the full text of the renewal applications on the Öko-Institut e.V. website - the report compiled by the Institute that was submitted to the EU council is available here.

Finally, on the 18th May 2018, the Commission issued Directive 2018/741 - this renews Exemption 6(c) to the 21st July 2021.

Now that the legislation has been updated, the same process of renewal applications will begin again within the specified time periods stated within the legislation. Note that because no feasible alternative to free-machining brass has yet entered the market, it is expected that Exemption 6(c) will be put forward for another renewal in the not-too-distant future.


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