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What are the Maximum Containment Values (MCVs) for these Metals in Products?

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The MCVs under California’s RoHS law are the same as those that apply to the EU’s RoHS Directive. For lead, mercury, and hexavalent chromium the MCV is 0.1% by weight. The MCV for cadmium is 0.01% by weight.

The MCVs apply to each “homogeneous material” used in the manufacture of covered electronic devices, rather than to the entire covered electronic device or specific components or specific components of the covered electronic device. The European Parliament and Commission has defined “homogeneous material” as follows:

A homogeneous material means a material that can not be mechanically disjointed into different materials.

  • The term “homogeneous” means “of uniform composition throughout”. Examples of homogeneous materials are individual types of plastics, ceramics, glass, metals, alloys, paper, board, resins and coatings.
  • The term “mechanically disjointed” means that the materials can, in principle, be separated by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes.


  • A plastic cover is a “homogeneous material” if it consists of one type of plastic that is not coated with or has attached to it, or inside it, any other kinds of materials. In this case, the MCVs would apply to the entire plastic cover.
  • An electric cable that consists of metal wires surrounded by non-metallic insulation materials is an example of a “non-homogeneous material” because the different materials could be separated by mechanical processes. In this case the MCVs would apply to each of the separated materials individually.
  • A semi-conductor package contains many homogeneous materials which include plastic, moulding material, tin electroplating coatings on the lead frame, the lead frame alloy and gold-bonding wires. In this case the MCVs would apply to each of the homogeneous materials that comprise the semi-conductor package.


  • The RoHS prohibition does not apply to a covered electronic device sold or offered for sale in California only for purposes of or offering for resale to persons outside of California.
  • Any application of cadmium, chromium, lead, or mercury, or any component containing any of those metals, that is exempted from the EU RoHS Directive, or by an amendment to that Directive, is also exempt from California’s RoHS Law.
  • The sale of a covered electronic device that contains an otherwise prohibited substance is exempt from California’s RoHS Law if that substance was used to comply with consumer, health, or safety requirements as are required by the Underwriters Laboratories, the federal government, or the state.

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