19-0415 v3.1 Lighting Included or Excluded?
Is lighting excluded from the Red List requirement or not? I was looking through Exceptions, and I understand small electrical components are excluded, but lighting is not directly called out. I also noticed that the ingredient Polychlorinated biphenyl was added to the list in V3, which can be found in lighting components such as ballasts.
There is no blanket ruling with respect to lighting fixtures, which depending on the building type and application, can have a wide range of characteristics. However, there are three basic components to consider: wiring, electrical components, and housing.
Standard voltage wiring in the light is subject to the Red List, but per the Furniture, Fixtures, and Equipment clarification, anything connected to low voltage wiring is not subject to the Materials Petal requirements.
The electrical components can be evaluated to determine whether they fall within the I10-E2 5/2013 Small Electrical Components Exception and if so, would then be subject to RoHS requirements, but in any event, the housing would not be subject to the Exception and would still need to be vetted and tracked.
The fixture connections might be considered Miscellaneous Hardware. Per the Institute's response to Dialogue Post, Miscellaneous Hardware (Part VI), Miscellaneous Hardware includes: "Outlet boxes, outlet cover plates, box extensions, switch cover plates, switch boxes, ﬂoor boxes, and octagon electrical boxes are considered miscellaneous hardware. GFCI’s, regular electrical receptacle outlets, light switches, wall box dimmers, and fan speed controls are also typically considered to be miscellaneous hardware, though more complex examples that include a circuit board are considered small electrical components and would need to meet RoHS guidelines. Miscellaneous hardware and small electrical components are not tracked for either Imperative 11 or 14. However, miscellaneous hardware that is known to be primarily composed of Red List ingredients, such as PVC electrical boxes, should be avoided".
Also note that in some cases, a component that contains Red List ingredients, could be used through I10-E1 8/2008 General Red List Exception. In addition, an element that makes up less than 100 ppm (or .01%) of a component or fixture is not subject to Materials Petal requirements.