Managing Hazardous Waste

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RoHS Lighting Applications

The RoHS Directive and Lighting Equipment

The RoHS Directive contains exemptions allowing mercury and certain applications of lead in lighting. All other hazardous substances may not exceed the MCV as a percentage by weight per homogenous material (please see RoHS Directive exemptions for more details. DTSC has created several flow charts as guidance outlining when these exemptions may be applicable).

The RoHS Directive contains many exemptions that may apply to lighting equipment, which are summarized below:

  • RoHS Application 1. Mercury in compact fluorescent lamps (CFLs) may not exceed 5 mg per lamp.
  • RoHS Application 2. Mercury in a straight fluorescent lamp that is used for general purpose may not exceed:
  • RoHS Application 3. No restrictions on the amount of mercury in a straight fluorescent lamp that is used for special purposes.
  • RoHS Application 4. No restrictions on the amount of mercury in other lamps not mentioned in RoHS Directive Annex.
  • RoHS Application 5. No restrictions on the amount of lead in the glass of fluorescent tubes.
  • RoHS Application 6. Lead used as an alloying element in steel can contain up to 0.35% lead by weight, 0.4% lead by weight for aluminum and 4% lead by weight for copper alloy.
  • RoHS Application 7. No restrictions on lead used in high melting temperature type solders (i.e. tin-lead based alloys containing 85% by weight or more lead).
  • RoHS Application 19. No restrictions on lead used in linear incandescent lamps with silicate coated tubes.
  • RoHS Application 22. No restrictions on lead with PbBiSn-Hg and PbInSn-Hg in specific compositions as main amalgam and with PbSn-Hg as auxiliary amalgam in very compact Energy Saving Lamps (ESL).

California modeled its Lighting Toxics Reduction law after the European Union’s (EU) RoHS Directive 2002/95/EC. Specific lighting applications of lead, mercury, cadmium and hexavalent chromium that are exempt from the EU RoHS Directive may also be exempt from California law. It is very important to consult both the actual California law and RoHS Directive provisions to when determining whether an exemption applies.

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