EU RoHS
April 8, 2020 | Written by GreenSoft Technology, Inc.
Multiple EU RoHS Exemptions Updated or Extended
Dozens of EU RoHS exemptions set to expire have been updated or temporarily extended during deliberations
In 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.