New Updates to the active EU RoHS Exemptions List

December 5, 2019|Written by GreenSoft Technology, Inc.

Two EU RoHS Exemptions have been updated by ECHA

EU-RoHSIn November, the European Chemicals Agency (ECHA) issued two updates to the list of active 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 have been updated with new expiration dates, so keeping track of the various dates and exemptions is a time-consuming task.

The two newly updated exemptions are:

  • In Annex III to Directive 2011/65/EU, the following entry 43 is added:

Bis(2-ethylhexyl) phthalate in rubber components in engine systems, designed for use in equipment that is not intended solely for consumer use and provided that no plasticised material comes into contact with human mucous membranes or into prolonged contact with human skin and the concentration value of bis(2-ethylhexyl) phthalate does not exceed:

(a) 30 % by weight of the rubber for

(i) gasket coatings;

(ii) solid-rubber gaskets; or

(iii) rubber components included in assemblies of at least three components using electrical, mechanical or hydraulic energy to do work, and attached to the engine.

(b) 10 % by weight of the rubber for rubber-containing components not referred to in point (a).

For the purposes of this entry, “prolonged contact with human skin” means continuous contact of more than 10 minutes duration or intermittent contact over a period of 30 minutes, per day.

Applies to category 11 and expires on 21 July 2024.


  • In Annex III to Directive 2011/65/EU, the following entry 44 is added:

Lead in solder of sensors, actuators, and engine control units of combustion engines within the scope of Regulation (EU) 2016/1628 of the European Parliament and of the Council (*1), installed in equipment used at fixed positions while in operation which is designed for professionals, but also used by non-professional users.

Applies to category 11 and expires on 21 July 2024.


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

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 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.

GreenSoft Keeps Track of RoHS-2 Exemptions So You Don’t Have To

Updates and exemptions to regulations occur regularly. With the status and timing of exemption extensions unknown, compliance can be a continually moving target.

Affected companies using parts or materials that utilize expiring exemptions 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 RoHS-2 and EN 50581.

Learn more about our RoHS-2 Data Services or contact us today to get started.

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