EU RoHS

May 11, 2026 | Written by GreenSoft Technology, Inc.

EU RoHS Pack 29: Assessment Project Started for Annex III and Annex IV Exemptions

New review of mercury exemptions and lead exemptions launched

The European Commission has contracted the Öko-Institut e.V. Institute for Applied Ecology to perform a new EU RoHS exemptions assessment project – Pack 29. The study will assess ten Annex III renewal requests for mercury in special purpose gas discharge lamps and three Annex IV revocation requests related to leaded glass and lead in detectors and amplification devices. A stakeholder consultation is planned for May 2026.

The launch of Pack 29 is significant because it targets several long-standing EU RoHS exemptions. Any changes to these exemptions could affect product design, material selection, and supply chain continuity across multiple industries. GreenSoft’s Regulatory Compliance Team tracks these developments closely and helps companies understand how evolving RoHS requirements may impact their components and compliance obligations.

Annex III exemption renewal requests under review

The Annex III renewal requests focus on mercury exemptions for various lamp types and specified mercury limits:

• 1(f) – I “Lamps emitting mainly light in the ultraviolet spectrum: 5 mg Hg”
• 2(b)(4)- II “Lamps emitting mainly light in the ultraviolet spectrum: 15 mg Hg”
• 2(b)(4)-III “Emergency lamps: 15 mg”
• 4(a)-I “Mercury in low pressure non-phosphor coated discharge lamps up to 15 mg Hg”
• 4(c) “Mercury in other High-Pressure Sodium (Vapour) Lamps (in 3 variants)”
• 4(f)-II: “Mercury in high pressure mercury vapour lamps (used in projectors)”
• 4(f)-III: “Mercury in high pressure mercury vapour lamps (used for horticulture lighting)”
• 4(f)-IV “Mercury ultraviolet lamps”

Annex IV exemption revocation requests under review

Annex IV revocation requests target lead exemptions and leaded glass in specialized applications:

• 1 “Lead, cadmium and mercury in detectors for ionising radiation”
• 1a “Lead and cadmium in ion selective electrodes including glass of pH electrodes”
• 3 “Lead in electromagnetic radiation amplification devices: micro-channel plate and capillary plate”

Stakeholder consultation and timeline

A stakeholder consultation will be launched in May 2026. Registered stakeholders will be notified when the consultation opens and can submit technical evidence, functional need justifications, and data on alternatives. Register here if you have not already done so to receive consultation materials and submission templates.

What Manufacturers can do now

RoHS exemption outcomes affect product design, procurement, and EU market access. Here are some actions manufacturers and compliance teams can take now to prepare:

• Register as a stakeholder to receive consultation notices.
• Prepare technical dossiers documenting functional need, performance requirements, and availability of alternatives.
• Assess supply chain risk for components relying on the listed exemptions and identify potential substitutes or redesign paths.
• Plan testing and qualification timelines in case exemptions are not renewed.
• Use consolidated exemption resources such as GreenSoft’s RoHS Exemption List to track changes.

How to stay updated on EU RoHS Exemptions

GreenSoft’s Regulatory Compliance Team continuously tracks and analyses EU RoHS developments, including exemption reviews like Pack 29, to identify implications for manufacturers and supply chains. Subscribe to our blog to receive timely updates on the status of Pack 29, consultation openings, and regulatory outcomes.

We also maintain a complete list of all current, valid EU RoHS exemptions and corresponding UK RoHS exemptions for easy reference. You can download our combined RoHS Exemptions List for free.

How GreenSoft can help

Regulatory updates and exemption decisions occur frequently, and tracking exemption expiry dates, status changes, and documentation can be time-consuming. If an exemption you rely on expires, you should begin sourcing replacements and phasing out affected parts immediately. Greensoft can help with that process through sourcing replacement parts, collecting substance data for components, and formatting the data to meet EU RoHS due diligence requirements.

Learn more about our EU RoHS Data Services or Contact us to get started with a personalized demo.