EU: Three RoHS exemptions under consultation

 

The EU Commission has notified public consultations about RoHS exemptions.

Under EU rules, certain hazardous substances are restricted in electrical and electronic equipment. Specific, time-limited exemptions can be granted upon request from businesses or organisations if the necessary criteria are met.

• The first exemption under assessment concerns lead as an alloying element in steel, aluminium and copper, which are used to manufacture electrical and electronic equipment.
• The second exemption under assessment concerns lead in glass or in ceramic of electrical or electronic components, including dielectric ceramic in capacitors.
• The third exemption under assessment concerns lead in high melting temperature type solders used in electrical and electronic equipment.

The feedback period is open till the 10 February 2025.

What Are RoHS Exemptions?

RoHS exemptions allow the use of restricted substances in certain applications where their removal or substitution is technically impractical or where no viable alternatives exist. These exemptions are vital for enabling innovation and maintaining functionality in specific industries, such as healthcare, renewable energy, and telecommunications.

Key Features of RoHS Exemptions

1. Temporary in Nature:
   Exemptions are not permanent. They are granted for a limited time and are subject to regular review. Manufacturers must reapply for exemptions to demonstrate the ongoing necessity.
2. Technical Justification:
   Exemptions are granted only when the applicant provides evidence that no viable substitute exists, and that the use of the restricted substance is essential for functionality or safety.
3. Specific Applications:
   Exemptions apply to defined uses of restricted substances, not to entire products or categories. For instance, lead may be allowed in certain types of solder for medical devices but not for general electronics.
4. Environmental and Health Balance:
   Applications for exemptions must include an assessment of the environmental, health, and safety impacts of the restricted substance compared to potential alternatives.

Common Exemptions

Some commonly granted RoHS exemptions include:

• Lead in high-reliability solder applications, such as aerospace and military equipment.
• Mercury in certain fluorescent lamps where energy efficiency cannot be achieved without it.
• Cadmium in photoresistors for professional equipment.
• Hexavalent Chromium for corrosion prevention in specific metal coatings.

Managing and Reviewing Exemptions

RoHS exemptions are evaluated under Annex III and Annex IV of the directive. Annex III applies to general EEE, while Annex IV focuses on medical devices and monitoring and control instruments.

The review process includes:

• Application Submission: Stakeholders, such as manufacturers or industry groups, submit a request for an exemption or renewal.
• Stakeholder Consultation: Public consultations are conducted to gather input from industry experts, NGOs, and other stakeholders.
• Technical and Scientific Evaluation: An independent technical review determines if the criteria for granting or renewing the exemption are met.
• Decision Making: The European Commission decides whether to grant, renew, or deny the exemption.

To find out more about product compliance in the EU and the RoHS compliance, please do not hesitate to contact the Product Compliance Institute.