RoHS Exemptions Renewals Update

25 June 2019

circuit-board-973311_1920A coalition of over 30 trade associations that represent the interests of manufacturers of electrical and electronic equipment has been formed to prepare and submit RoHS exemption renewal requests. Taking the name of “the Umbrella Project”, the coalition comprises of Working Groups that are tasked with preparing renewal requests for many of the exemptions in Annex III of the RoHS Directive. Such renewal requests need to be submitted at least 18 months before they expire as this serves to ensure that the exemptions will remain valid until the European Commission publishes decisions in the Official Journal to renewal or not.

Previously, in 2014-15, trade associations requested renewals for many Annex III exemptions, but only for category 1-7 and 10 types of electrical and electronic equipment. This time, the exemption expiry dates are the same for categories 1-7 and 10 as for category 8 medical devices and for non-industrial category 9, and so manufacturers and their trade associations for these categories of equipment are collaborating to write renewal requests. In-vitro diagnostic (IVD) medical devices and industrial category 9 have later expiry dates and so do not need to submit renewals until later. However, the majority of the Annex III exemptions are for electronic components which most manufacturers use in similar ways and so some trade associations in the IVD medical and industrial category 9 sectors have joined the Umbrella Project.

Working Groups (WGs) have been set up for 4f, 6a, 6b, 6c, 7a, 7cI, 7cII, 7cIV, 8b, 13a, 13b, 15 and 34 although others could be set up should the need arise. WGs have been very busy and are making good progress. WG chairpersons who co-ordinate the activities of each individual WG have asked for examples of uses of exempted RoHS substances and also to receive results of attempts to identify alternatives, especially where this was not successful. Where available, this evidence will be particularly valuable in supporting renewal requests. It is necessary that each exemption is clearly justified to be renewed and this will require clear evidence from applicants. If any manufacturers have useful data, please contact the appropriate WG or your trade association, who can pass it on to the correct chairperson.

Many Annex IV exemptions will also expire in 2021 and so renewal requests will need to be made by category 8 medical devices and non-industrial category 9 manufacturers before January 2020 or earlier dates for the few exemptions which have earlier expiry dates. The Umbrella Project does not include Annex IV exemptions although discussions are taking place between trade associations to determine how they can collaborate.


Picture of Dr Paul Goodman, Principal Regulatory Consultant, Rina

Written by Dr Paul Goodman, Principal Regulatory Consultant, Rina

Paul provides consultancy on global environmental and technical legislation including the EU RoHS, WEEE, and Eco-design directives and the REACH regulations. He assists many clients to determine their obligations and to deal with their implications. He regularly presents papers on regulatory compliance issues at international conferences. He has worked on several projects for the European Commission on the RoHS directive, Ecodesign and critical raw materials. He regularly advises the UK government on issues relating to electrical equipment and legislation and is a member of the EU RoHS Additional Substances Working Group. Paul is a chemist with expertise in materials used in electrical equipment and has carried out numerous investigations into a wide variety of reliability issues and failures of electronic equipment, has written reviews on electrical contacts and connectors, soldering, microelectronics and is a regular contributor to ERA Technology’s environmental newsletter “RE4view”.