EU RoHS
April 1, 2024 | Written by GreenSoft Technology, Inc.
EU RoHS Exemptions Timeline Update
Updates on critical EU RoHS exemptions expected in third quarter 2024
The European Commission has announced a target adoption date of third quarter 2024 for pending EU RoHS exemptions, including critical exemptions such as 7(a), 7(c)-i, and 6(a).
These EU RoHS exemptions, many of which are essential for electronics manufacturers, have been pending since January 2020.
The list of exemptions and their current statuses can be found on the European Commission website here, and is detailed in the table below:
| Exemption | Description | Status |
|---|---|---|
| 7(a) | Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead) | Under review for all product categories |
| 7(c)-i | Electrical and electronic components containing lead in a glass or ceramic other than dielectric ceramic in capacitors, e.g. piezoelectronic devices, or in a glass or ceramic matrix compound | Under review for all product categories |
| 7(c)-ii | Lead in dielectric ceramic in capacitors for a rated voltage of 125 V AC or 250 V DC or higher | Under review for all product categories |
| 6(a) | Lead as an alloying element in steel for machining purposes and in galvanised steel containing up to 0,35 % lead by weight | Expired for Categories 1-7 and 10, Under review for renewal for categories 8-9 and 11 |
| 6(a)-i | Lead as an alloying element in steel for machining purposes containing up to 0,35 % lead by weight and in batch hot dip galvanised steel components containing up to 0,2 % lead by weight | Under review for renewal for categories 1-7 and 10, not applicable to categories 8-9 and 11 |
| 6(b) | Lead as an alloying element in aluminium containing up to 0,4 % lead by weight | Expired for Categories 1-7 and 10, Under review for renewal for categories 8-9 and 11 |
| 6(b)-i | Lead as an alloying element in aluminium containing up to 0,4 % lead by weight, provided it stems from lead-bearing aluminium scrap recycling | Under review for renewal for categories 1-7 and 10, not applicable to categories 8-9 and 11 |
| 6(b)-ii | Lead as an alloying element in aluminium for machining purposes with a lead content up to 0,4 % by weight | Under review for renewal for categories 1-7 and 10, not applicable to categories 8-9 and 11 |
| 6(c) | Copper alloy containing up to 4 % lead by weight | Under review for all product categories |
EU RoHS exemptions have been pending since 2020
Under the EU RoHS Directive, if an extension is requested for an expiring exemption, then the exemption remains valid until a decision on the exemption request has been made by the European Commission. Extensions must be submitted no later than 18 months before the existing exemption expiration date.
Exemption requests were made by industry stakeholders in January 2020 for the critical EU RoHS exemptions listed above. Those exemptions were set to expire in July 2021, but because of the exemption requests, the exemptions have remained in force.
Since January 2020, the European Commission has been studying the exemptions, and contracted the Oko-Institut e.V. to provide recommendations on which exemptions should be renewed. That Oko-Institut e.V. recommendations report was published in February 2022; however, the Commission has yet to make an official decision on any of the exemptions.
This new announcement of the target adoption dates for the exemptions indicates that the European Commission intends to make a decision by the end of the year for these exemptions. However, the decision may or may not align with the Oko-Institut e.V. recommendations. Additionally, the European Commission has missed similar target adoptions dates in the past, and it is possible that no such announcements will be made until 2025.
GreenSoft can help with EU RoHS compliance
With the status and timing of EU RoHS exemption extensions unknown, keeping track of the various expiration dates and current exemptions is a complicated task. Companies should prepare and plan for a time when they can no longer apply such exemptions, as the exemptions could expire as soon as 12 months after the European Commission's exemption review decision if the exemption is not renewed.
EU RoHS compliance is mandatory for affected companies that manufacture or distribute products in the European market. Failure to comply with EU RoHS can result in loss of market access, supply chain disruptions, and other serious consequences for manufacturers and distributors.
GreenSoft Technology provides personalized Data Services and GreenData Manager software to help electronics manufacturers with EU RoHS compliance. We’ll collect data on the chemicals contained in your products so that you can ensure you’re complying with the EU RoHS Directive.
Additionally, GreenSoft Technology 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. You can download the updated EU RoHS Exemptions List here.
Learn more about our environmental compliance Data Services or contact us today to get started.
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