All you need to Know About the Latest EU RoHS Exemption List

All you need to Know About the Latest EU RoHS Exemption List

Staying abreast of the recent compliance certification directives can be daunting for many manufacturing companies due to the evolving nature of the compliance and regulatory landscape. In case you are wondering what’s new with the EU’s list of Restriction of Certain Harmful Substances (RoHS) in the Hazardous Substances Directives in electrical and electronic equipment that manufacturers or suppliers need to keep note of, we have some news for you!

First, what is the role of the RoHS Directive?

RoHS was first anchored under the EU Directive 2011/65. The RoHS certification confirms if the electrical or electronic products contain safe proportions of substances or materials that are hazardous and difficult to dispose of. The hazardous list of substances includes but is not limited to lead, mercury, hexavalent chromium, and cadmium which have far-reaching impacts on the environment and health of communities that are frequently exposed.

Manufacturers of electronic devices are instructed to use safer and environmental-safe alternatives to these hazardous substances. They are required to mention the details of components and their proportions in technical documentation as per DIN EN 50581 directive. In 2011, the EU directed manufacturers to use CE-certified products that satisfy the applicable requirements under the community harmonization legislation, upon its installation.

What’s Changed with RoHS Exemption List?

In March 2020, the European Commission revised the EU’s RoHS exemptions, and manufacturers or producers of electrical and electronic supplies are allowed to apply for exemptions under Annexes III and IV for substance restriction limits under certain applications and uses. However, the expiration dates for exemptions vary and are likely to have expired in 2021. Many industry participants have reportedly pushed for its renewal.

Refer to the status of renewal requests and notices in the downloadable list available on the European Commission’s website. Additionally, you can view the renewal dossiers for exemptions on the COCIR European Trade site. For detailed updates on the restricted substances and new exemptions, download the final report.

Expected Updates on Key EU RoHS Exemptions in the Third Quarter of 2024

Exemptions under Annex III have historically allowed companies to continue using lead where no viable alternatives exist.

However, the latest RoHS updates signal a major shift towards phase-outs and targeted exemptions rather than blanket renewals.

• (i) Immediate Revocations (12-18 Month Phase-Outs) Several key exemptions for lead in steel and aluminum alloys will not be renewed, giving industries just 12-18 months to transition: 6(a): Lead in steel for machining and galvanization. 6(b), 6(b)-I, 6(b)-II: Lead in aluminum alloys and machining applications (for general use).

These short phase-out periods mean companies must immediately assess supply chain risks, as lead-free alternatives must be sourced before the exemptions expire.

• (ii) Exemptions Renewed Until December 31, 2026 Some exemptions will remain until the end of 2026, providing limited breathing room: 6(a)-I & 6(a)-II: Lead in machining steel and batch hot-dip galvanized steel. 6(b)-I & 6(b)-II: Lead in aluminum for industrial applications (categories 9 & 11 only). 6(b)-III: A new exemption for lead in aluminum casting alloys (≤0.3% from recycled scrap). 6(c): Lead in copper alloys (≤4%). 7(a): Lead in high-melting-temperature solders (≥85% lead). 7(c)-I: Lead in glass/ceramic matrix components. While these exemptions remain in effect for now, businesses should not assume they will be renewed indefinitely—proactive research into alternative materials and processes is necessary.

• (iii) Exemptions Extended Until December 31, 2027 (More Narrowly Defined) Certain exemptions for high-melting-temperature solders and ceramic/glass applications have been extended, but with very specific criteria: 7(a)-I to 7(a)-VII: Focused on very specific applications in semiconductors, PCB assembly, and electrical connections. 7(c)-II: Lead in dielectric ceramic capacitors (≥125V AC / 250V DC). 7(c)-V: Lead in glass matrix components (used for electrical insulation, bonding, resistive materials). 7(c)-VI: Lead in ceramics for piezoelectric applications (PZT) and positive temperature coefficient (PTC) ceramics. These targeted sub-exemptions suggest that broad lead exemptions are becoming a thing of the past—future renewals will likely be granted only for very specific, highly technical use cases.

RoHS Exemption Procedure

The Directive allows for exemptions from its restrictions, under certain conditions defined in Article 5(1), adapting the Annexes to scientific and technical progress.

Exemptions are granted on a case-by-case basis and are limited in time. They must be reassessed on a regular basis to ensure that they remain necessary and appropriate. When reassessing an exemption, the following factors are taken into account:

• The availability, practicability, and reliability of substitutes
• The environmental, health, and consumer safety impacts of substitution
• The socioeconomic impact of substitution
• Any potential adverse impacts on innovation Industry stakeholders can apply for exemptions or for the renewal of existing exemptions. An application for renewal of an exemption must be made no later than 18 months before the exemption expires. Each request is evaluated on its own merits, and when appropriate, an exemption is granted.

Assessment studies are conducted to evaluate the impact of substances on human health and the environment. These studies are used to determine whether an exemption is necessary and appropriate. The results of these studies are publicly available and can be accessed by stakeholders and the general public.

Acquis supports you in RoHS compliance specific to your country with a slew of IT solutions and services that design, automate, and speed up the process.

Learn more about our EU RoHS compliance support or contact us to help you get started!