EU RoHS

June 21, 2017 | Written by GreenSoft Technology, Inc.

European Commission Extends Three RoHS-2 Exemptions

Three Annex III RoHS-2 Exemptions Extended Until 2019-2024; Still No Decision on Others

As we previously reported, many of the most commonly used exemptions applicable to product categories 1-7 and 10 of the EU RoHS-2 Directive were set to expire on July 21, 2016. However, a large number of extension applications for exemptions were submitted to the European Commission, and, per the RoHS-2 Directive, exemptions remain in effect until a decision is made on extension applications that have been submitted.

Earlier this month, the Commission officially published three RoHS-2 Annex III exemption extensions. This set of exemptions is collectively known as "Pack 7." With this decision, the exemptions are now extended through July 2019 to 2024, depending on the substance and product category (see below).

The Commission has still not published any decisions on the remaining exemption extension requests. A list of pending exemption extension requests can be found here.

Pack 7 Exemptions Concerning Use of Lead and Cadmium

The three Pack 7 exemptions that have been extended concern the use of lead and cadmium in reflective and optical glass, and the use of lead in bearing shells and bushes for compressors.

These new exemption extensions now expire on a gradual scale on July 21 in 2019, 2021, 2023 and 2024 depending on the substance and product category.

• Commission Delegated Directive (EU) 2017/1009 modifies and extends exemption 13(b) of Annex III (Cadmium and lead in filter glasses and glasses used for reflective standards.) This exemption has been divided up with sunset dates set by type of optical glass as well as product category. Due to this change, new exemptions 13(b)-I, 13(b)-II, and 13(b)-III have been implemented. The new exemption definitions become mandatory on July 6, 2018. Producers who have been using exemption 13(b) in the past should review the impact of this change as it relates to their products.
• Commission Delegated Directive (EU) 2017/1011 extends exemption 13(a) of Annex III (Lead in white glasses used for optical applications) until July 21, 2021 for most categories, July 21, 2023 for category 8 devices, and July 21, 2024 for category 9 and 11 devices. Because no change was made to the definition of this exemption, producers who have been using exemption 13(a) can continue to do so until the updated sunset dates are reached.
• Commission Delegated Directive (EU) 2017/1010 extends and modifies exemption 9(b) of Annex III (Lead in bearing shells and bushes for certain refrigerant-containing compressors.) This exemption has been divided up with sunset dates set by compressor design as well as product category. Due to this change, exemption 9(b)-I has been implemented. The new exemption definitions become mandatory on July 6, 2018. The revised exemption only applies to product categories 8, 9, and 11, as well as certain equipment under category 1. Producers who have been using exemption 9(b) in the past should review the impact of this change on their specific products.

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

Updates and exemptions to regulations are common and to be expected. 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 Services or contact us today to get started!