Multiple EU RoHS Exemptions Updated or Extended

April 8, 2020Written by GreenSoft Technology, Inc.

Dozens of EU RoHS exemptions set to expire have been updated or temporarily extended during deliberations

eu-rohsIn March, the European Commission issued multiple updates to the list of EU RoHS exemptions.

Under Annexes III and IV of the EU RoHS Directive, producers of electronic equipment may be permitted to apply exemptions to substance restriction thresholds for certain specific uses and applications.

However, exemptions have varying expiration dates, and many exemptions that were set to expire in 2021 have been requested for renewal by industry stakeholders.

While the EU Commission is considering renewals for each exemption, the expiration dates for those exemptions are temporarily extended until the Commission reaches a final decision. If the Commission approves the renewal request for the exemptions, a new expiration date will be assigned to each renewed exemption at that time. For product categories that are not impacted by the renewals, the existing expiration rate remains in effect.

The Commission’s online notice of the renewal requests can be found in a downloadable list on their website. You can also find renewal dossiers for most exemptions on the COCIR European trade association website.

We have compiled the exemptions that the EU Commission is considering for renewal in the table below. For a more detailed table with substance descriptions and expiration dates for each category 1 through 11, download the full EU RoHS Exemptions List compiled by GreenSoft.

EU RoHS Exemptions Under Consideration for Renewal
Annex III (Standard exemptions)

Exemption Reference Exempted Substances Impacted Product Categories Renewal Request Date
4a Mercury 8 (excluding In vitro), 9 (excluding Industrial) January 17, 2020
4f Mercury 8 (excluding In vitro), 9 (excluding Industrial) January 17, 2020
6a Lead 8, 9 January 17, 2020
6a1 Lead 1-7, 10 January 17, 2020
6b Lead 8, 9 January 17, 2020
6b1 Lead 1-7, 10 December 3, 2019
6b2 Lead 1-7, 10 November 8, 2019
6c Lead 1-10 January 3, 2020
7a Lead 1-7, 10 January 6, 2020
7c1 Lead 1-10 January 2, 2020
7c2 Lead 1-10 March 1, 2020
8b Cadmium 8, 9 March 1, 2020
8b1 Cadmium 1-7, 10 March 1, 2020
13a Lead 1-11 November 28, 2019
13b Lead and Cadmium 8, 9, 11 November 28, 2019
13b1 Lead 1-7, 10 November 28, 2019
13b2 Cadmium 1-7, 10 November 28, 2019
13b3 Cadmium and lead 1-7, 10 November 28, 2019
15 Lead 8, 9 March 1, 2020
15a Lead 1-7, 10 March 1, 2020
18b Lead 1-7, 8 (excluding In vitro), 9 (excluding Industrial), 10 March 1, 2020
18b1 Lead 5 March 1, 2020
29 Lead 1-7, 10, 11 March 1, 2020
32 Lead 1-7, 8 (excluding In vitro), 9, 10 March 1, 2020
34 Lead 1-10 January 15, 2020

EU RoHS Exemptions Under Consideration for Renewal
Annex IV (Medical device exemptions)

Exemption Name Exempted Substances Impacted Product Categories Renewal Request Date
1 Lead, Cadmium, Mercury 8 (excluding In vitro), 9 January 2, 2020
1a Lead, Cadmium 8 (excluding In vitro), 9 January 17, 2020
1b Lead 8 (excluding In vitro), 9 January 15, 2020
1c Lead, Cadmium, Mercury 8, 9 November 22, 2019
2 Lead 8 (excluding In vitro), 9 (excluding Industrial) January 15, 2020
3 Lead 8, 9 January 18, 2020
5 Lead 8 (excluding In vitro), 9 January 6, 2020
11 Lead 8 (excluding In vitro), 9 (excluding Industrial) January 2, 2020
12 Lead, Cadmium 8 (excluding In vitro), 9 July 31, 2019
13 Lead 8 (excluding In vitro), 9 (excluding Industrial) January 15, 2020
14 Lead 8 (excluding In vitro), 9 (excluding Industrial) January 2, 2020
15 Lead 8 (excluding In vitro), 9 (excluding Industrial) January 15, 2020
17 Lead 8 (excluding In vitro), 9 (excluding Industrial) January 15, 2020
18 Lead 8 (excluding In vitro), 9 (excluding Industrial) January 15, 2020
20 Cadmium 8 (excluding In vitro), 9 (excluding Industrial) December 20, 2019
26 Lead 8 (excluding In vitro), 9 December 11, 2019
27 Lead 8, 9 (excluding Industrial) December 12, 2018
29 Lead 8 (excluding In vitro), 9 (excluding Industrial) December 20, 2019
31a Lead, Cadmium, Hexavalent Chromium and Polybrominated Diphenylethers (PBDEs) 8, 9 (excluding Industrial) January 2, 2020
39 Lead 8, 9 January 18, 2020

In addition to the exemption renewals under consideration, the EU Commission has also issued formal decisions on several other exemptions. The table below lists the newly added or updated exemptions issued by the Commission. For a more detailed table with substance descriptions and updated expiration dates for all product categories, download the full EU RoHS Exemptions List compiled by GreenSoft.

Updated & Newly Added EU RoHS Exemptions
Annex III (Standard exemptions)

Exemption Reference Exempted Substances Impacted Product Categories Apply Date Type Delegated
Directive
9 Hexavalent Chromium 1-11 March 5, 2020 Update Link
9a1 Hexavalent Chromium 1-7, 10 April 1, 2021 Newly added Link
9a2 Hexavalent Chromium 1-7, 10 April 1, 2021 Newly added Link
41 Lead 1-11 April 1, 2021 Update Link

Updated & Newly Added EU RoHS Exemptions
Annex IV (Medical device exemptions)

Exemption Reference Exempted Substances Impacted Product Categories Apply Date Type Delegated
Directive
37 Lead 8, 9 April 1, 2021 Update Link
41 Lead 8 (In vitro only) April 1, 2021 Update Link
44 Cadmium 9 September 1, 2020 Newly added Link

These exemption updates were published in the Official Journal of the European Union on 5 March 2020. The last prior batch of EU RoHS exemption updates was in November 2019.

GreenSoft keeps track of RoHS exemptions for you

GreenSoft maintains a compiled list of the EU RoHS Exemptions in order to perform EU RoHS Data Services for our customers and to keep our GreenData Manager software up-to-date. We also make this list available online to the public for your convenience and reference.

Our compiled EU RoHS Exemptions List has been updated to include the recent changes by the European Commission. You can download the updated EU RoHS Exemptions List here.

Updates and exemptions to regulations occur regularly. With the status and timing of exemption extensions unknown, keeping track of the various dates and exemptions is a time-consuming task.

Affected companies using parts or materials that utilize expiring exemptions that were not extended should immediately begin finding replacements and phasing out the use of those parts or materials.

GreenSoft can help with this process, including the sourcing of replacement parts. We can help you collect the substance data on your parts and format the data to meet the due diligence and documentation requirements of EU RoHS and EN 50581.

Learn more about our EU RoHS Data Services or contact us today to get started.

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