Concern丨A new item of hexavalent chromium is proposed to be added to the EU RoHS exemption list

On June 22, 2022, the European Commission submitted a notification G/TBT/N/EU/903 to the TBT Committee of the WTO, intending to add anticorrosion as a gas absorption heat pump to Annex III (Exemption List) of the EU RoHS Directive Hexavalent Chromium Exemption Clause for Agents.

The new exemption clauses are as follows:

background

On 23 December 2020, the European Commission received an application under Article 5(3) of Directive 2011/65/EU for the use of hexavalent chromium as a corrosion inhibitor in the working fluid of carbon steel sealing circuits of gas absorption heat pumps Use the exemptions listed in Annex III of the Directive. Gas absorption heat pumps require electricity for auxiliary functions, such as pumping a working fluid into the system. The gas absorption heat pump described in the request for exemption falls under Category 1 "Large electrical appliances" of Annex I of Directive 2011/65/EU.

The evaluation of the exemption application included a technical and scientific evaluation study that concluded that it is currently not scientifically and technically feasible to replace hexavalent chromium in refrigerant solutions, while other eliminations use hexavalent chromium in the form of sodium chromate. 's heating technology does not provide equivalent functionality and performance. Gas absorption heat pumps can indeed provide greater energy efficiency than condensing boiler technology, can help replace these systems, and can reduce carbon dioxide emissions.

The assessment therefore concludes that at least one of the relevant conditions set out in point 5(1)(a) of Directive 2011/65/EU on the environmental, health and The total negative impact on consumer safety may outweigh its total environmental, health and consumer safety benefits. The maximum concentration of hexavalent chromium in the refrigerant solution is 0.7% by weight, which is considered sufficient to meet the required exemption requirements.

Warm Tips

The revision of EU RoHS exemption clauses has a great impact on the electrical and electronic related industries, especially whether some exemption clauses frequently used by enterprises are extended or not, which may directly affect the production process and business activities of enterprises. In order to ensure the compliance of entering the EU market, ZRLK recommends that relevant companies always pay attention to the update of the exemption clauses of the RoHS Directive, make reasonable arrangements for production plans and material substitution, and avoid compliance problems caused by the expiration of exemptions for products exported to Europe. Our company has a professional technical team and rich experience in the control of hazardous substances, which can help you easily understand whether the product is safe and compliant. If you need it, please feel free to contact us, and our engineers will serve you as soon as possible!