Miles Free, director of industry research and technology at the Precision Machined Products Association in Cleveland, told Lube Report, The [European] Parliament still has to take final action, but the commission’s announcement of the Draft Delegated Directives about continuing the lead exemptions was a very positive step. But when you are dealing with regulators, I have learned to expect anything.

The European Parliament is responsible for the Restriction on the use of certain Hazardous Substances (RoHS). Effective July 1, 2006, RoHS declared lead, cadmium, mercury, hexavalent chrome, etc. to be hazardous substances. Although the tendency for lead to accumulate – along with its neurological effects and toxicity – motivate regulatory limitations, traces of lead in alloys substantially reduce friction during machining operations, increase throughput, reduce power consumption and extend tool service life.

The final version of RoHS contained an exemption that limited lead to 0.35 percent by weight in steel, 0.4 percent in aluminum alloys and 4 percent in copper alloys, such as brasses and bronzes, for use in appliances, certain electric and electronic equipment and many other products.

A draft of the next-generation legislation, RoHS 2, would have restricted lead levels to no more than 0.1 percent by weight in alloys for a much broader range of products. The lead exemption was scheduled to expire July 21, 2016. However, an application requesting the renewal of the lead exemption was submitted in January 2015. The parliament was expected to respond by January 2016 and either agree to renew the lead exemption or instead impose the 0.1 weight percent limitation sometime between Jan. 21 and July 21, 2017.

If implemented, this regulatory change would have affected American machine shops that import leaded steels, aluminum alloys and brasses from Europe and those that export individual parts and components of assembled products to markets in the EU. Metalworking fluid manufacturers would have scrambled to evaluate and probably reformulate metalworking and metal removal fluids for use with new low-lead alloys and more demanding machining conditions for these alloys.

Parliament postponed its announcement of a ruling on the lead exemption until mid-April, 2016. But no further information was forthcoming, and 2016 passed into 2017 without an update on the lead exemption to RoHS.

On Sept. 19, 2017, the European Commission published three draft delegated directives that propose continuing the RoHS exemption for lead. The directives propose extending the RoHS exemption for steel and copper alloys through July 21, 2021 for product categories 1-7 and 10 in Annex 3 of RoHS II (household appliances, electric tools, consumer and lighting equipment, toys, etc.) Expiration dates are more generous for categories 8 (medical devices) and 9 (monitoring equipment).

Free noted that the situation is less clear for aluminum alloys. The exemption for aluminum alloys deliberately produced with lead for machining purposes will expire three years after the publication of the delegated directive in the Official Journal. This allows time for the metalworking industry to assess lead-free alternatives and adapt their processes. But the timeline is uncertain.

The three RoHS exemption directives may be viewed online at the following European Commission web site links: for lead as an alloying element in steel, for lead as an alloying element in copper and for lead as an alloying element in aluminum. There is a four-week window for feedback, acknowledged or anonymous, via the website.