I've been coordinating with Chris Daly of Stereo Coffee who also builds/sells an LDR based DIY preamp board. We have clear common interest in supporting a favorable resolution to the ability to sell products containing LDRs into the EU. What follows is an update that Chris recently posted on DIYAudio in response to a direct inquiry to the EU on the subject.
Based on the timely response from the EU it would appear that we have been cleared for the continued use of photoresistors for analogue optocouplers for sale into the EU although some confusion remains given that the specific exemption for LDRs did run out at the end of 2013. It appears that expiration notwithstanding, that by virtue of a directive that became effective in January, 2013 that LDRs are allowed by virtue of there still being no other substitute materials for the cadmium sulphide presently used in their construction.
What follows here is the EU's response letter text plus some additional commentary by Chris.
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Dear Mr Daly,
Thank you for your message.
The Commission Directive 2012/51/EU has enabled the use of cadmium in photoresistors for analogue optocouplers as an exemption from the ROHS directive. Therefore, indeed, the use of cadmium in photoresistors for analogue optocouplers is currently allowed as there are no other substitutes. We draw your attention in this context to the recitals of the Directive:
http://eur-lex.europa.eu/legal-conte...LEX:32012L0051This new delegated Directive is based on the Recast of the RoHS Directive which entered into force in January 2013. The information relating to the recast of this Directive with the comments submitted during the public consultation is available on the following website of the Directorate-General for the Environment:
http://ec.europa.eu/environment/wast...e/index_en.htmIf you wish to voice your opinion on waste management issues and changes to the EU legislation, we invite you to consult the public consultations webpage on DG Environment:
Consultations - Environment - European Commission
We hope you find this information useful. Please contact us again if you have other questions.
With kind regards,
EUROPE DIRECT Contact Centre
EUROPA ? EU website | Choose your language | Choisir une langue | Wählen Sie eine Sprache - your shortcut to the EU!
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Chris's commentary....
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A further letter addressed to the National Measurement Office UK asking as to any restriction applying to and relying on ROHS directives will be provided to this forum when it becomes available. It is likely in a similar manner to the EU reply that it will be found that there is no restriction to photoresistors for analogue optocouplers as there is currently no replacement or equivalent product available. If anything changes we at Stereo Coffee will be pleased to let you know. Are LDR pres the ultimate passive? - Page 11 contains further discussion.
Common sense applies to LDR's don't chew or smoke your LDR's. Further information discussing the encapsulated casings is at the above forum, which are entirely safe if used as supplied in our kits.
If you choose to shatter the casings scrape back the lens cover and expose yourself to the resistive coating that is an entirely different matter, as is the disassembly of camera light meters, street lights, clock radios, alarm devices, night lights, outdoor clocks, solar street lamps and solar road studs and high powered loudspeaker voice coils, etc also containing cadmium sulphide.