Issue: Insufficient lead substances present for classification 3.5
The material in question is classified as 3.5 Lead; but contains less than 50% of the substances in the basic substance group, Lead or its compounds,*
Per IMDS Recommendation 001a** – Classification 3.5 should ONLY be used when there is almost 100% lead in a material for example in accumulators or lead coatings. It can also be used in solders with more than 80% lead content.
NOTE: enerally speaking solder may contain 0.1% Pb or less or 85% Pb or more. ELV Annex II allows only the following exemptions for Pb in solder for new parts:
- 8(e). Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead)
- 8(f)(b). Lead in compliant pin connector systems other than the mating area of vehicle harness connectors
- Scope and Expiry Date: Vehicles type-approved before 1 January 2024 and spare parts for these vehicles
- 8(k). Soldering of heating applications with 0,5 A or more of heat current per related solder joint to single panes of laminated glazings not exceeding wall thickness of 2,1 mm. This exemption does not cover soldering to contacts embedded in the intermediate polymer
- Scope and Expiry Date: Vehicles type approved before 1 January 2024 and spare parts for these vehicles
All other exemptions for Pb in solder apply only to legacy spare parts.
Action Required:
Review the material composition and classification and revise as necessary.
If the material is a solder being used in a new part and there is no applicable exemption code, contact your customer to discuss the issue.
*You can find the substances in a basic substance group using the Substance Search function in IMDS.
*IMDS Recommendations may be downloaded from inside IMDS at Help > Recommendation.