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The European directive 2002/95/EC was originally published on 27th January 2003 and came into force on 13th February 2003. It required that EC member states transpose the directive into their national law by 13th August 2004 so that new electrical and electronic equipment (‘which is dependant on an electric current in order to work properly’), put on the market from 1st July 2006 did not contain ANY lead, mercury, cadmium, hexavalent chromium, poly-brominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE).
This effectively out-lawed most materials, including stainless steels, as they are bound to contain some lead, mercury and cadmium, however small this might be, even though these elements are not deliberately added in the steelmaking processes.
This flaw in the wording of the European directive has now been rectified in the Official Journal of the European Union document C(2005) 3143, 2005/618/EC, published on 18th August 2005. (Copies of EC directives are available on the Department of Trade and Industry web site, www.dti.gov.uk)
The maximum allowed concentrations by weight of lead, mercury, hexavalent chromium, poly-brominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE) for materials that include stainless steels has now been set at 0.1%.
Cadmium is restricted to a 0.01% maximum.
In stainless steels only the restrictions to the elements lead, mercury and cadmium are relevant.
Stainless steels do not contain ANY hexavalent chromium, poly-brominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE). The minimum 10.5% chromium content in stainless steels is present mainly in the metallic state or, in much smaller quantities, combined with other elements like carbon as carbides or intermetallic compounds such as sigma ‘phase’. The chromium content of stainless steels is therefore NOT subject to RoHS restrictions.
Analysis work was originally done on lead, mercury and cadmium levels by the Scandanavian stainless steel producers (then AvestaPolarit, now Outokumpu Stainless and Sandvik Steel) when the end of life vehicles ‘ELV’ directive restrictions were imposed in 2003.
This showed that the steels tested had values for lead, mercury and cadmium well below the directive’s maximum levels.
The restriction levels in the ELV are same as here in the RoHS and so commercially produced stainless steels can be expected to comply with these latest RoHS requirements, without actual values being measured or declared by the steelmaker or supplier.