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What are the RoHS concerns related to aluminum products?

The issue with aluminum and RoHS is that some aluminum alloys, such as 2011, contain lead in amounts which could exceed the 0.4% allowed by the exemption in clause 6 of the Annex of the RoHS directive. Fortunately, the alloys we use for standard parts do not contain any intentional additions of lead and therefore have always been RoHS compliant. With regards to chromium, any chromium present in aluminum will be in the metallic or zero valence state and is therefore not an RoHS concern since the RoHS directive restricts only hexavalent chromium which only exists in certain compounds in which the chromium has a valence state of +6 (hexavalent). A chromate finish applied to aluminum could contain hexavalent compounds. We do not apply any type of chromate finish to any of our standard aluminum products.

Does the RoHS Directive ban the use of cadmium plating on fasteners?

Yes, cadmium plating is not RoHS compliant. Although clause 8 of the Annex of the original RoHS Directive (2002/95/EC) granted an exemption allowing cadmium plating to be used in some aerospace applications and other safety critical applications, the current Directive no longer allows any exemption for cadmium plating. Cadmium is also a REACH SVHC and cadmium plating on any of our fasteners will always exceed the allowable REACH threshold of 0.1 % of article weight.

Does the RoHS Directive ban all chromium?

Chromium can exist in four states. Metallic, divalent, trivalent and hexavalant. In some compounds chromium is in the hexavalent state (valence of +6) and many of these compounds are hazardous. The current European RoHS Directive bans the use of six substances, one of which is hexavalent chromium. The ban on hexavalent chromium targets primarily corrosion resistant coatings, such as the chromate conversion coatings applied to zinc plating. Metallic chromium found in stainless steel is not a RoHS substance.

What type of chromium is in the conversion coating applied to zinc plating?

The substance of concern with regard to chromate conversion coatings on zinc plating and RoHS compliance is hexavalent chromium. The RoHS Directive restricts hexavalent chromium, but does not restrict less hazardous trivalent chromium. Historically, both clear and yellow chromate conversion coatings contained hexavalent chromium compounds. In recent years suppliers of chromate conversion coating materials have been working hard to develop chromate conversion coatings that contain only trivalent chromium compounds and provide acceptable corrosion resistance. Presently there are a number of such products available in clear. Yellow chromates have been more difficult to develop because the corrosion resistance requirements are greater. For example, ASTM B 633 requires 12 hours of neutral salt spray to white corrosion for clear chromate, but 96 hours for yellow chromate. With regard to our standard zinc plated PEM brand steel fasteners, we began using a trivalent clear chromate in June of 2002 for all our product with finish suffix ZI. Therefore all -ZI product plated after June 2002 is RoHS compliant. Also, we began using trivalent chromate in our optional zinc and yellow (suffix -ZC) plating on March 1, 2006. Therefore, this finish is compliant as of that date.

How does PennEngineering determine the RoHS compliant status of the hexavalent chrome used in the conversion coating for zinc and zinc alloy platings?

PennEngineering uses the detection methods defined in the IEC-63321-7-1:2015 to measure hexavalent chrome in the chromate conversion (passivation) layer of our zinc-chromate plated parts to assure they are not hexavalent chromium based as determined by IEC-62321-7-1:2015 and other consensus standards.

What type of chromium is in stainless steel?

In stainless steel, chromium is in the metallic state, which is not hazardous.

What type of chromium is in the oxide layer created by passivating stainless steel?

Our research has found this layer to be dichromium trioxide or Cr2O3, which is a trivalent compound as opposed to chromium trioxide or CrO3, which is a hexavalent compound.

What does the term “Lead Free” mean?

The term “Lead Free” can have two meanings. First. it could simply mean that the product has no lead. Secondly, it could mean that the material is compatible with a lead free soldering process. In the second case the process must be specified.

What are the specific lead exemptions that relate to fasteners and how are these exemptions currently addressed by PennEngineering?

The overwhelming majority of PennEngineering’s products are lead free. Other products are compliant by exemption. More specifically:

Exemption 6a – Some PennEngineering parts are machined from leaded steel and use European RoHS exemption 6a. In the latest version of the European RoHS Directive, sometimes referred to as the RoHS recast or RoHS II, exemption 6a is still valid with no expiration date currently set. Parts using exemption 6a are therefore fully compliant with the European RoHS Directive and will remain so until such time as exemption 6a expires. We continue to closely monitor the status of exemption 6a and will take prompt action if and when an expiration date is set. However, if you currently require lead free steel options, they are available with associated costs. Contact [email protected] for more information.

Exemption 6c – Some PennEngineering parts are machined from leaded brass and use European RoHS exemption 6c. In the version of the European RoHS Directive currently in effect, sometimes referred to as the RoHS recast or RoHS II, exemption 6c is still valid. A review of exemption 6c is currently in process and the EC (European Commission) is expected to extend it, but even if they do not, it will remain in effect for at least 12 months from the date of their decision. Parts using exemption 6c are therefore fully compliant with the European RoHS Directive and will remain so until such time as exemption 6c is removed. However, if you currently require lead free brass or can utilize other lead free materials such as steel, stainless steel or aluminum, there are options that we can discuss. Again, there may be associated costs. Contact [email protected] for more information.

Do you use any non-compliant plastics in any of your products?

No. All of the plastic used in our locking and hybrid products are RoHS compliant.