RoHS exemptions are currently under revision

Economic operators concerned, such as manufacturers, importers and fulfilment service providers, should keep themselves constantly informed about the development of RoHS exemptions. Since numerous RoHS exemptions are reportable under REACh, violations of RoHS restrictions are transparent and publicly available when exemptions are eliminated.

The consultation period in the current stakeholder consultation on RoHS exemptions expired on 6 June. In this round, comments were received on eight exemptions concerning the lead content of electrical equipment components. It is not yet clear whether all eight exemptions will remain in place. Experience shows, however, that it will take 18 months before this is transposed into a legal act. Should any exemptions cease to apply, there will be a transitional period of at least 12 months.

Economic operators concerned, such as manufacturers, importers and fulfilment service providers, should keep themselves constantly informed about the development of RoHS exemptions. The “candidates” mentioned here include the following:

  • Lead in the glass of fluorescent tubes not exceeding 0.2% by weight
  • Lead as an activator in phosphor powder (1% lead by weight or less) in discharge lamps when used as sun-tanning lamps with fluorescent substances such as CLT
  • Lead as an activator in the fluorescent powder (1% lead by weight or less) of discharge lamps containing fluorescent substances such as CLT when used in medical phototherapy devices
  • Lead in solders for soldering on milled-through multilayer ceramic capacitors in disc and planar arrangements.
  • “Lead incorporated in crystal glass” as defined in Annex I (categories 1, 2, 3 and 4) to Council Directive 69/493/EEC
  • Lead oxide in sealing frit for the production of windows for argon and krypton lasers
  • Lead in cermet-based trim potentiometer elements.
  • Lead as an activator in the fluorescent powder of discharge lamps when used for extracorporeal photopheresis lamps containing CLT (BaSi2O5:Pb)

These RoHS exemptions are reportable under REACh and therefore transparent. If exemptions cease to apply, REACh notifications must therefore likewise be updated.

trade-e-bility supports you in compliance with statutory requirements such as RoHS and informs its customers about relevant statutory amendments. The trade-e-bility consultants will be pleased to assist you. Please call +49/40/750687-300 or send an e-mail message to beratung@trade-e-bility.de.