RoHS Exemption List

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New Amendments to the EU RoHS Exemptions Lists

The New List of General EU RoHS Exemptions (Annex III)*

Exemption # Description Scope and Expiration Dates (if any)
1 Mercury in single capped (compact) fluorescent lamps not exceeding: -
1a  For general lighting purposes < 30 W:  5 mg per burner. Expired December 31, 2011.  After December 31, 2011:  3.5 mg per burner. After December 31, 2012:  2.5 mg per burner.
Applies to categories 1 to 7 and 10.
1b  For general lighting purposes ≥ 30 W and < 50 W:  5 mg per burner.  Expired on December 31, 2011. After December 31, 2011:  3.5 mg per burner.
Applies to categories 1 to 7 and 10.
1c  For general lighting purposes ≥ 50 W and < 150 W:  5 mg per burner. Applies to categories 1 to 7 and 10.
1d  For general lighting purposes ≥ 150 W:  15 mg per burner Applies to categories 1 to 7 and 10.
1e  For general lighting purposes with circular or square structural shape and tube diameter ≤ 17 mm.   No limit until 2012. After December 31, 2011:  7 mg per burner
Applies to categories 1 to 7 and 10.
1f  For special purposes:  5 mg per burner Applies to categories 1 to 7 and 10.
1g For general lighting purposes less than 30 W with a lifetime equal or above 20,000 h: 3.5 mg. Applies to categories 1 to 7 and 10.
2a  Mercury in double-capped linear fluorescent lamps for general lighting purposes not exceeding: -
2a-I Tri-band phosphor with normal lifetime and a tube diameter < 9 mm (T2):  5 mg per lamp.  Expired December 31, 2011. After December 31, 2011:  4 mg per lamp.
Applies to categories 1 to 7 and 10.
2a-II Tri-band phosphor with normal lifetime and a tube diameter ≥ 9 mm and ≤ 17 mm (T5):  5 mg per lamp.  Expired on December 31, 2011. After December 31, 2011:  3 mg per lamp
Applies to categories 1 to 7 and 10.
2a-III Tri-band phosphor with normal lifetime and a tube diameter > 17 mm and ≤ 28 mm (T8):  5 mg per lamp.   Expired on December 31, 2011. After December 31, 2011:  3.5 mg per lamp
Applies to categories 1 to 7 and 10.
2a-IV Tri-band phosphor with normal lifetime and a tube diameter > 28 mm (T12):  5 mg per lamp.   Expired on December 31, 2012. After December 31, 2012:  3.5 mg per lamp
Applies to categories 1 to 7 and 10.
2a-V Tri-band phosphor with long lifetime (≥ 25 000 h):  8 mg per lamp Expired on December 31, 2011.  After December 31, 2011:  5 mg per lamp
Applies to categories 1 to 7 and 10.
2b Mercury in other fluorescent lamps not exceeding: -
2b-I Linear halophosphate lamps with tube > 28 mm (T10 and T12): 10 mg per lamp. Expired on April 13, 2012
2b-II Non-linear halophosphate lamps (all diameters):  15 mg per lamp. Expired on April 13, 2016
2b-III Non-linear tri-band phosphor lamps with tube diameter > 17 mm (T9). No limit until 2012.  After December 31, 2011:  15 mg per lamp.
Applies to categories 1 to 11. Expires on: — 21 July 2023 for category 8 in vitro diagnostic medical devices; — 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11 (other EEE).
2b-IV Lamps for other general lighting and special purposes (induction lamps). No limit until 2012.  After December 31, 2011: 15 mg per lamp
Applies to categories 1 to 11. Expires on: — 21 July 2023 for category 8 in vitro diagnostic medical devices; — 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11 (other EEE).
3 Mercury in cold cathode fluorescent lamps and external electrode fluorescent lamps (CCFL and EEFL) for special purposes not exceeding: -
3a Short length (≤ 500 mm).  No limit until 2012. After December 31, 2011:  3.5 mg per lamp
Applies to categories 1 to 11. Expires on: — 21 July 2023 for categories 8  in vitro diagnostic medical devices; — 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11 (other EEE).
3b  Medium length (> 500 mm and ≤ 1,500 mm).   No limit until 2012. After December 31, 2011:  7 mg per burner
Applies to categories 1 to 11. Expires on: — 21 July 2023 for categories 8  in vitro diagnostic medical devices; — 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11 (other EEE).
3c Long length (> 1 500 mm).  No limit until 2012. After December 31, 2011:  13 mg per lamp
Applies to categories 1 to 11. Expires on: — 21 July 2023 for categories 8  in vitro diagnostic medical devices; — 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11 (other EEE).
4a  Mercury in other low pressure discharge lamps.   No limit until 2012. After December 31, 2011: 15 mg per lamp
Applies to categories 1 to 11. Expires on: — 21 July 2023 for categories 8  in vitro diagnostic medical devices; — 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11 (other EEE).
4b  Mercury in high pressure sodium (vapor) lamps for general lighting purposes in lamps with improved color rendering index Ra > 60 not exceeding: -
4b-I  P ≤ 155 W.   No limit until 2012.  After December 31, 2011:  30 mg per burner
Applies to categories 1 to 7 and 10.
4b-II  155 W < P ≤ 405 W.   No limit until 2012. After December 31, 2011:  40 mg per burner
Applies to categories 1 to 7 and 10.
4b-III P > 405 W.   No limit until 2012.  After December 31, 2011:  40 mg per burner
Applies to categories 1 to 7 and 10.
4c  Mercury in other high pressure sodium (vapor) lamps for general lighting purposes not exceeding: -
4c-I  P ≤ 155 W.   No limit until 2012.  After December 31, 2011:  25 mg per burner
Applies to categories 1 to 7 and 10.
4c-II  155 W < P ≤ 405 W.   No limit until 2012. After December 31, 2011:  30 mg per burner
Applies to categories 1 to 7 and 10.
4c-III  P > 405 W.  No limit until 2012.  After December 31, 2011:  40 mg per burner
Applies to categories 1 to 7 and 10.
4d  Mercury in high pressure mercury (vapor) lamps (HPMV). Expired on April 13, 2015
4e Mercury in metal halide lamps (MH). Applies to categories 1 to 7, 10 and 11. Expires on: — 21 July 2023 for categories 8  in vitro diagnostic medical devices; — 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11 (other EEE).
4f Mercury in other discharge lamps for special purposes not specifically mentioned. Applies to categories 1 to 11. Expires on: — 21 July 2023 for categories 8  in vitro diagnostic medical devices; — 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11 (other EEE).
4g Mercury in hand crafted luminous discharge tubes used for signs, decorative or architectural and specialist lighting and light-artwork, where the mercury content shall be limited as follows: (a) 20 mg per electrode pair + 0,3 mg per tube length in cm, but not more than 80 mg, for outdoor applications and indoor applications exposed to temperatures below 20 °C; (b) 15 mg per electrode pair + 0,24 mg per tube length in cm, but not more than 80 mg, for all other indoor applications. Expired on 31 December 2018
5a Lead in glass of cathode ray tubes. Applies to categories 8 (in vitro diagnostic medical devices) 9 (industrial monitoring and control instruments), and 11 (other EEE).  Expires on: — 21 July 2023 for categories 8 (in vitro diagnostic medical devices); — 21 July 2024 for category 9 (industrial monitoring and control instruments), and for category 11 (other EEE).
5b Lead in glass of fluorescent tubes not exceeding 0.2 % by weight. Applies to categories 8 (in vitro diagnostic medical devices) 9 (industrial monitoring and control instruments), and 11 (other EEE).  Expires on: — 21 July 2023 for categories 8 (in vitro diagnostic medical devices); — 21 July 2024 for category 9 (industrial monitoring and control instruments), and for category 11 (other EEE).
6a Lead as an alloying element in steel for machining purposes and in galvanized steel containing up to 0.35 % lead by weight. Applies to categories 8, 9 and 11.  Expires on:  — 21 July 2024 for category 11 (other EEE).
6a-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 Applies to categories 1 to 7 and 10.
6b Lead as an alloying element in aluminum containing up to 0.4 % lead by weight Applies to categories 8 (in vitro diagnostic medical devices) 9 (industrial monitoring and control instruments), and 11 (other EEE).  Expires on: — 21 July 2024 for category 11 (other EEE).
6b-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. Applies to categories 1 to 7 and 10.
6b-II Lead as an alloying element in aluminium for machining purposes with a lead content up to 0.4 % by weight. Applies to categories 1 to 7 and 10.
6c Copper alloy containing up to 4 % lead by weight. Applies to categories 1-7, 10 and 11. Expires on: — 21 July 2024 for category 11 (other EEE).
7a Lead in high melting temperature type solders (lead-based alloys containing 85 % by weight or more lead). Applies to categories 1-7, 10 and 11. Expires on: — 21 July 2024 for category 11 (other EEE).
7b Lead in solders for servers, storage and storage array systems, network infrastructure equipment for switching, signaling, transmission, and network management for telecommunications. Applies to categories 8 (in vitro diagnostic medical devices) 9 (industrial monitoring and control instruments), and 11 (other EEE).  Expires on: — 21 July 2023 for categories 8 (in vitro diagnostic medical devices); — 21 July 2024 for category 9 (industrial monitoring and control instruments), and for category 11 (other EEE).
7c-I  Electrical and electronic components containing lead in a glass or ceramic other than dielectric ceramic in capacitors (piezoelectronic devices) or in a glass or ceramic matrix compound. Applies to categories 1 to 11. Expires on: — 21 July 2024 for category 11 (other EEE).
7c-II  Lead in dielectric ceramic in capacitors for a rated voltage of 125 V AC or 250 V DC or higher Applies to categories 1 to 11. Expires on: — 21 July 2024 for category 11 (other EEE).
7c-III  Lead in dielectric ceramic in capacitors for a rated voltage of less than 125 V AC or 250 V DC.   Expired on January 1, 2013
7c-IV Lead in PZT-based dielectric ceramic materials for capacitors being part of integrated circuits or discrete semiconductors. Applies to categories 8 (in vitro diagnostic medical devices) 9 (industrial monitoring and control instruments), and 11 (other EEE).  Expires on: — 21 July 2023 for categories 8 (in vitro diagnostic medical devices); — 21 July 2024 for category 9 (industrial monitoring and control instruments), and for category 11 (other EEE).
8a Cadmium and its compounds in one shot pellet type thermal cut-offs. Expired January 1, 2012.
8b Cadmium and its compounds in electrical contacts. Applies to categories 8 , 9, and 11.  Expires on: — 21 July 2024 for category 11 (other EEE).
8b-I Cadmium and its compounds in electrical contacts
used in:
— circuit breakers,
— thermal sensing controls,
— thermal motor protectors (excluding hermetic thermal motor protectors),
— AC switches rated at:
     - 6 A and more at 250 V AC and more, or
     - 12 A and more at 125 V AC and more,
— DC switches rated at 20 A and more at 18 V DC and more, and
— switches for use at voltage supply frequency ≥ 200 Hz. 
Applies to categories 1 to 7 and 10.
9 Hexavalent chromium as an anticorrosion agent of the carbon steel cooling system in absorption refrigerators up to 0.75 % by weight in the cooling solution Applies to categories 8 (in vitro diagnostic medical devices) 9 (industrial monitoring and control instruments), and 11 (other EEE).  Expires on: — 21 July 2024 for category 11 (other EEE).
9A1 Up to 0,75% hexavalent chromium by weight, used as an anticorrosion agent in the cooling solution of carbon steel cooling systems of absorption refrigerators (including minibars) designed to operate fully or partly with electrical heater, having an average utilised power input < 75 W at constant running conditions Expired March 5, 2021.
9A2 Up to 0,75% hexavalent chromium by weight, used as an anticorrosion agent in the cooling solution of carbon steel cooling systems of absorption refrigerators:
- designed to operate fully or partly with electrical heater, having an average utilised power input ≥ 75 W at constant running conditions;
- designed to fully operate with non-electrical heater.
Applies to categories 1 to 7 and 10.
9b Lead in bearing shells and bushes for refrigerant-containing compressors for heating, ventilation, air conditioning and refrigeration (HVACR) applications. Applies to categories 8 (in vitro diagnostic medical devices) 9 (industrial monitoring and control instruments), and 11 (other EEE).  Expires on: — 21 July 2023 for categories 8 (in vitro diagnostic medical devices); — 21 July 2024 for category 9 (industrial monitoring and control instruments), and for category 11 (other EEE).
9b-I Lead in bearing shells and bushes for refrigerant- containing hermetic scroll compressors with a stated electrical power input equal or below 9 kW for heating, ventilation, air conditioning and refrigeration (HVACR) applications. Expired July 21, 2019
11a Lead used in C-press compliant pin connector systems. Expired September 24, 2010
11b Lead used in other than C-press compliant pin connector systems. Expired January 1, 2013
12 Lead as a coating material for the thermal conduction module C-ring. Expired September 24, 2010
13a Lead in white glasses used for optical applications. Applies to categories 1 to 11
13b Cadmium and lead in filter glasses and glasses used for reflectance standards. Applies to categories 8, 9 and 11
13b-I Lead in ion coloured optical filter glass types. Applies to categories 1 to 7 and 10
13b-II Cadmium in striking optical filter glass types; excluding applications falling under point 39. Applies to categories 1 to 7 and 10
13b-III Cadmium and lead in glazes used for reflectance standards. Applies to categories 1 to 7 and 10
14 Lead in solders consisting of more than two elements for the connection between pins and package of microprocessors with lead content of more than 80% and less than 85% by weight.  Expired January 1, 2011.
15 Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit flip chip packages. Applies to categories 8, 9 and 11 and expires on 21 July 2024 for category 11 (other EEE)
15a Lead in solders to complete a viable electrical connection between the semiconductor die and carrier within integrated circuit flip chip packages where at least one of the following criteria applies:
— a semiconductor technology node of 90 nm or larger;
— a single die of 300 mm2 or larger in any semiconductor technology node;
— stacked die packages with die of 300 mm2 or larger, or silicon interposers of 300 mm2 or larger.
As of March 1st 2020: applies to categories 1 to 7 and 10.
16 Lead in linear incandescent lamps with silicate coated tubes. Expired on September 1, 2013
17 Lead halide as radiant agent in high intensity discharge (HID) lamps used for professional reprography applications Expires on: — 21 July 2023 for category 8 in vitro diagnostic medical devices; — 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.
18a  Lead as activator in the fluorescent powder (1 % lead by weight or less) of discharge lamps when used as specialty lamps for diazoprinting reprography, lithography, insect traps, photochemical and curing processes containing phosphors such as SMS.   Expired January 1, 2011
18b  Lead as activator in the fluorescent powder (1 % lead by weight or less) of discharge lamps when used as sun tanning lamps containing phosphors such as BSP  (BaSi2O5:Pb). Applies to categories 1 to 11. Expires on: — 21 July 2023 for categories 8  in vitro diagnostic medical devices; — 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.
18b-I Lead as activator in the fluorescent powder (1 % lead by weight or less) of discharge lamps containing phosphors such as BSP (BaSi2O5:Pb) when used in medical phototherapy equipment As of March 1st 2020: applies to category 5. See entry 34 of Annex IV for category 8.
19 Lead with PbBiSn-Hg and PbInSn-Hg in specific compositions as main amalgam and with PbSn-Hg as auxiliary amalgam in very compact energy saving lamps (ESL).   Expired June 1, 2011
20 Lead oxide in glass used for bonding front & rear substrates of flat fluorescent lamps used for liquid crystal displays (LCD).   Expired June 1, 2011
21 Lead and cadmium in printing inks for the application of enamels on glasses, such as borosilicate and soda lime glasses. Applies to categories 8 (in vitro diagnostic medical devices), 9 (industrial monitoring and control instruments) and 11 (other EEE) and expires on: — 21 July 2023 for category 8 in vitro diagnostic medical devices; — 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11 (other EEE).
21a Cadmium when used in colour printed glass to provide filtering functions, used as a component in lighting applications installed in displays and control panels of EEE. Expired on 21 July 2021.
21b Cadmium in printing inks for the application of enamels on glasses, such as borosilicate and soda lime glasses. Expired on 21 July 2021.
21c Lead in printing inks for the application of enamels on other than borosilicate glasses. Expired on 21 July 2021.
23 Lead in finishes of fine pitch components other than connectors with a pitch of 0.65 mm and less.   Expired September 24, 2010.
24 Lead in solders for the soldering to machined through hole discoidal or planar array ceramic multilayer capacitors. Applies to categories 1 to 11. Expires on: 21 July 2024 for category 11 (other EEE)
25 Lead oxide in surface conduction electron emitter displays (SED) used in structural elements, notably in the seal frit and frit ring. Applies to categories 8 (in vitro diagnostic medical devices), 9 (industrial monitoring and control instruments) and 11 (other EEE) and expires on: — 21 July 2023 for category 8 in vitro diagnostic medical devices; — 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11 (other EEE).
26 Lead oxide in the glass envelope of black light blue lamps. Expired June 1,  2011
27 Lead alloys as solder for transducers used in high-powered loudspeakers designated to operate for several hours at acoustic power levels of 125 dB SPL and above.   Expired September 24, 2010
29 Lead bound in crystal glass as defined in Annex I (Categories 1, 2, 3, 4) of Directive 69/493/EEC. Applies to categories 1 to 7, 8 (in vitro diagnostic medical devices), 9 (industrial monitoring and control instruments), 10, and 11 (other EEE). Expires on: — 21 July 2023 for categories 8  in vitro diagnostic medical devices; — 21 July 2024 for category 9 industrial monitoring and control instruments.
30 Cadmium alloys as electrical/mechanical solder joints to electrical conductors located directly on the voice coil in transducers used in high-powered loudspeakers with sound pressure levels of 100 dB (A) and more. Expires on: — 21 July 2023 for category 8 in vitro diagnostic medical devices, — 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11 (EEE). 
31 Lead in soldering materials in mercury free flat fluorescent lamps (used for liquid crystal displays, design or industrial lighting). Expires on: — 21 July 2023 for category 8 in vitro diagnostic medical devices, — 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11 (EEE). 
32 Lead oxide in seal frit used for making window assemblies for Argon and Krypton laser tubes. Applies to categories 1 to 11. Expires on: — 21 July 2023 for categories 8  in vitro diagnostic medical devices; — 21 July 2024 for category 11 (other EEE).
33 Lead in solders for the soldering of thin copper wires of 100 µm diameter and less in power transformers. Applies to categories 8 (in vitro diagnostic medical devices), 9 (industrial monitoring and control instruments) and 11 (other EEE). Expires on: — 21 July 2023 for category 8 in vitro diagnostic medical devices; — 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11 (other EEE).
34 Lead in cermet-based trimmer potentiometer elements. Applies to categories 1 to 11
36 Mercury used as a cathode sputtering inhibitor in DC plasma displays with a content up to 30 mg per display.  Expired July 1, 2010
37 Lead in the plating layer of high voltage diodes on the basis of a zinc borate glass body. Applies to categories 8 (in vitro diagnostic medical devices), 9 (industrial monitoring and control instruments) and 11 (other EEE). Expires on: — 21 July 2023 for category 8 in vitro diagnostic medical devices; — 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.
38 Cadmium and cadmium oxide in thick film pastes used on aluminum bonded beryllium oxide. Applies to categories 8 (in vitro diagnostic medical devices), 9 (industrial monitoring and control instruments) and 11 (other EEE). Expires on: — 21 July 2023 for category 8 in vitro diagnostic medical devices; — 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.
39 Cadmium in color converting II-VI LEDs (< 10 μg Cd per
mm of light-emitting area) for use in solid state illumination or display systems.
Expired on November 20, 2018
39a Cadmium selenide in downshifting cadmium based semiconductor nanocrystal quantum dots for use in display
lighting applications (< 0.2 μg Cd per mm2
 of display screen area).
Applies to categories 1 to 11.
40 Cadmium in photoresistors for analogue optocouplers applied in professional audio equipment.   Expired on December 31, 2013
41 Lead in solders and termination finishes of electrical and electronic components and finishes of printed circuit boards used in ignition modules and other electrical and electronic engine control systems, which for technical reasons must be mounted directly on or in the crankcase or cylinder of hand-held combustion engines (classes SH:1, SH:2, SH:3 of Directive 97/68/EC of the European Parliament and of the Council. Applies to categories 1 to 7, 10 and 11. Expires on: — 31 March 2022 for categories 1 to 7, 10 and 11; — 21 July 2023 for category 8  in vitro diagnostic medical devices; — 21 July 2024 for category 9 industrial monitoring and control instruments.
42 Lead in bearings and bushes of diesel or gaseous fuel powered internal combustion engines applied in non-road professional use equipment:
— with engine total displacement ≥ 15 litres;
or
— with engine total displacement < 15 litres and the engine is designed to operate in applications where the time between signal to start and full load is required to be less than 10 seconds; or regular maintenance is typically performed in a harsh and dirty outdoor environment, such as mining, construction, and agriculture applications.
Applies to category 11 (other EEE)

Expires on 21 July 2024.
43 Bis(2-ethylhexyl) phthalate (DEHP) in rubber components in engine systems, designed for use in equipment that is not intended solely for consumer use and provided that no plasticised material comes into contact with human mucous membranes or into prolonged contact with human skin and the concentration value of bis(2-ethylhexyl) phthalate does not exceed:
(a) 30 % by weight of the rubber for
      (i) gasket coatings;
      (ii) solid-rubber gaskets; or
      (iii) rubber components included in assemblies of at least three components using electrical, mechanical or hydraulic energy to do work, and attached to the engine.
(b) 10 % by weight of the rubber for rubber-containing components not referred to in point (a).
For the purposes of this entry, “prolonged contact with human skin” means continuous contact of more than 10 minutes duration or intermittent contact over a period of 30 minutes, per day.
Applies to category 11 (other EEE)

Expires on 21 July 2024.
44 Lead in solder of sensors, actuators, and engine control units of combustion engines within the scope of Regulation (EU) 2016/1628 of the European Parliament and of the Council, installed in equipment used at fixed positions while in operation which is designed for professionals, but also used by non-professional users Applies to category 11 (other EEE)

Expires on 21 July 2024.
45 Lead diazide, lead styphnate, lead dipicramate, orange lead (lead tetroxide), lead dioxide in electric and electronic initiators of explosives for civil (professional) use and barium chromate in long time pyrotechnic delay charges of electric initiators of explosives for civil (professional) use Decided. Not yet applied, For category 11 (other EEE)

Expires on 20 April 2026.

The New List of Exemptions Exclusively to Medical Devices and Monitoring and Control Instruments (Annex IV)*

Exemption # Description Scope and Expiration Dates (if any)
1 Lead, cadmium and mercury in detectors for ionising radiation. Applies to categories 8 and 9. Expires on: — 21 July 2023 for categories 8 (in vitro diagnostic medical devices).
1a Sensors, detectors and electrodes - Lead and cadmium in ion selective electrodes including glass of pH electrodes. Applies to categories 8 and 9. Expires on: — 21 July 2023 for categories 8 (in vitro diagnostic medical devices).
1b Sensors, detectors and electrodes - Lead anodes in electrochemical oxygen sensors. Applies to categories 8 and 9. Expires on: — 21 July 2023 for categories 8 (in vitro diagnostic medical devices).
1c Sensors, detectors and electrodes - Lead, cadmium and mercury in infra-red light detectors. Applies to categories 8 and 9.
1d Sensors, detectors and electrodes - Mercury in reference electrodes: low chloride mercury chloride, mercury sulphate and mercury oxide. Applies to categories 8 (other than in vitro diagnostic medical devices) and 9 (industrial monitoring and control instruments).
2 Equipment utilising or detecting ionising radiation - Lead bearings in X-ray tubes. Applies to categories 8 and 9. Expires on: — 21 July 2023 for categories 8 (in vitro diagnostic medical devices). — 21 July 2024 for category 9 (industrial monitoring and control instruments).
3 Equipment utilising or detecting ionising radiation - Lead in electromagnetic radiation amplification devices: micro-channel plate and capillary plate. Applies to categories 8 and 9.
4 Equipment utilising or detecting ionising radiation - Lead in glass frit of X-ray tubes and image intensifiers and lead in glass frit binder for assembly of gas lasers and for vacuum tubes that convert electromagnetic radiation into electrons. Applies to categories 8 (in vitro diagnostic medical devices) and 9 (industrial monitoring and control instruments). Expires on: — 21 July 2023 for categories 8 (in vitro diagnostic medical devices). — 21 July 2024 for category 9 (industrial monitoring and control instruments).
5 Equipment utilising or detecting ionising radiation - Lead in shielding for ionising radiation. Applies to categories 8 and 9 (industrial monitoring and control instruments). Expires on: — 21 July 2023 for categories 8 (in vitro diagnostic medical devices).
6 Equipment utilising or detecting ionising radiation - Lead in X-ray test objects. Applies to categories 8 (in vitro diagnostic medical devices) and 9 (industrial monitoring and control instruments). Expires on: — 21 July 2023 for category 8 (in vitro diagnostic medical devices). — 21 July 2024 for category 9 (industrial monitoring and control instruments).
7 Equipment utilising or detecting ionising radiation - Lead stearate X-ray diffraction crystals. Applies to categories 8 (in vitro diagnostic medical devices) and 9 (industrial monitoring and control instruments). Expires on: — 21 July 2023 for category 8 (in vitro diagnostic medical devices). — 21 July 2024 for category 9 (industrial monitoring and control instruments).
8 Equipment utilising or detecting ionising radiation - Radioactive cadmium isotope source for portable X-ray fluorescence spectrometers. Applies to categories 8 (in vitro diagnostic medical devices) and 9 (industrial monitoring and control instruments). Expires on: — 21 July 2023 for category 8 (in vitro diagnostic medical devices). — 21 July 2024 for category 9 (industrial monitoring and control instruments).
9 Others - Cadmium in helium-cadmium lasers. Applies to categories 8 (in vitro diagnostic medical devices) and 9 (industrial monitoring and control instruments). Expires on: — 21 July 2023 for category 8 (in vitro diagnostic medical devices). — 21 July 2024 for category 9 (industrial monitoring and control instruments).
10 Others - Lead and cadmium in atomic absorption spectroscopy lamps. Applies to categories 8 (in vitro diagnostic medical devices) and 9 (industrial monitoring and control instruments). Expires on: — 21 July 2023 for category 8 (in vitro diagnostic medical devices). — 21 July 2024 for category 9 (industrial monitoring and control instruments).
11 Others - Lead in alloys as a superconductor and thermal conductor in MRI. Applies to categories 8 (in vitro diagnostic medical devices) and 9 (industrial monitoring and control instruments). Expires on: — 21 July 2023 for categories 8 (in vitro diagnostic medical devices). — 21 July 2024 for category 9 (industrial monitoring and control instruments)
12 Lead and cadmium in metallic bonds creating superconducting magnetic circuits in MRI, SQUID, NMR (Nuclear Magnetic Resonance) or FTMS (Fourier Transform Mass Spectrometer) detectors. Applies to categories 8 (other than in vitro diagnostic medical devices) and 9 (industrial monitoring and control instruments).
13 Others - Lead in counterweights. Applies to categories 8 and 9. Expires on: — 21 July 2023 for categories 8 (in vitro diagnostic medical devices). — 21 July 2024 for category 9 (industrial monitoring and control instruments).
14 Others - Lead in single crystal piezoelectric materials for ultrasonic transducers. Applies to categories 8 and 9. Expires on: — 21 July 2023 for categories 8 (in vitro diagnostic medical devices). — 21 July 2024 for category 9 (industrial monitoring and control instruments).
15 Others - Lead in solders for bonding to ultrasonic transducers. Applies to categories 8 and 9. Expires on: — 21 July 2023 for categories 8 (in vitro diagnostic medical devices). — 21 July 2024 for category 9 (industrial monitoring and control instruments).
16 Others - Mercury in very high accuracy capacitance and loss measurement bridges and in high frequency RF switches and relays in monitoring and control instruments not exceeding 20 mg of mercury per switch or relay. Applies to categories 8 (in vitro diagnostic medical devices) and 9 (industrial monitoring and control instruments). Expires on: — 21 July 2023 for categories 8 (in vitro diagnostic medical devices). — 21 July 2024 for category 9 (industrial monitoring and control instruments)
17 Others - Lead in solders in portable emergency defibrillators. Applies to categories 8 and 9. Expires on: — 21 July 2023 for categories 8 (in vitro diagnostic medical devices). — 21 July 2024 for category 9 (industrial monitoring and control instruments).
18 Others - Lead in solders of high performance infrared imaging modules to detect in the range 8-14 µm. Applies to categories 8 and 9. Expires on: — 21 July 2023 for categories 8 (in vitro diagnostic medical devices). — 21 July 2024 for category 9 (industrial monitoring and control instruments).
19 Others - Lead in Liquid crystal on silicon (LCoS) displays. Applies to categories 8 (in vitro diagnostic medical devices) and 9 (industrial monitoring and control instruments). Expires on: — 21 July 2023 for categories 8 (in vitro diagnostic medical devices). — 21 July 2024 for category 9 (industrial monitoring and control instruments)
20 Others - Cadmium in X-ray measurement filters. Applies to categories 8 and 9. Expires on: — 21 July 2023 for categories 8 (in vitro diagnostic medical devices). — 21 July 2024 for category 9 (industrial monitoring and control instruments).
21 Cadmium in phosphor coatings in image intensifiers for X-ray images until 31 December 2019 and in spare parts for X-ray systems placed on the EU market before 1 January 2020. Expired on 31 December 2019
22 Lead acetate marker for use in stereotactic head frames for use with CT and MRI and in positioning systems for gamma beam and particle therapy equipment. Expired on 30 June 2021
23 Lead as an alloying element for bearings and wear surfaces in medical equipment exposed to ionising radiation. Expired on 30 June 2021
24 Lead enabling vacuum tight connections between aluminium and steel in X-ray image intensifiers.  Expired on 31 December 2019
25 Lead in the surface coatings of pin connector systems requiring nonmagnetic connectors which are used durably at a temperature below -20°C under normal operating and storage conditions. Expired on 30 June 2021
26 Lead in the following applications that are used durably at a temperature below - 20 °C under normal operating and storage conditions: (a) solders on printed circuit boards; (b) termination coatings of electrical and electronic components and coatings of printed circuit boards; (c) solders for connecting wires and cables; (d) solders connecting transducers and sensors. Lead in solders of electrical connections to temperature measurement sensors in devices which are designed to be used periodically at temperatures below - 150 °C. Applies to categories 8 (other than in vitro diagnostic medical devices) and 9.
27 Lead in solders, termination coatings of electrical and electronic components and printed circuit boards, connections of electrical wires, shields and enclosed connectors, which are used in (a) magnetic fields within the sphere of 1 m radius around the isocenter of the magnet in medical magnetic resonance imaging equipment, including patient monitors designed to be used within this sphere, or (b) magnetic fields within 1 m distance from the external surfaces of cyclotron magnets, magnets for beam transport and beam direction control applied for particle therapy. Applies to categories 8 and 9 (other than industrial monitoring and control instruments).
28 Lead in solders for mounting cadmium telluride and cadmium zinc telluride digital array detectors to printed circuit boards. Expired on 31 December 2017
29 Lead in alloys, as a superconductor or thermal conductor, used in cryo-cooler cold heads and/or in cryo-cooled cold probes and/or in cryo-cooled equipotential bonding systems, in medical devices (category 8) and/or in industrial monitoring and control instruments. Applies to categories 8 (other than in vitro diagnostic medical devices) and 9 (other than industrial monitoring and control instruments).
30 Hexavalent chromium in alkali dispensers used to create photocathodes in X-ray image intensifiers until 31 December 2019 and in spare parts for X-ray systems placed on the EU market before 1 January 2020. Expired on 31 December 2019
31 Lead, cadmium and hexavalent chromium in reused spare parts, recovered from medical devices placed on the market before 22 July 2014 and used in category 8 equipment placed on the market before 22 July 2021, provided that reuse takes place in auditable closed-loop business-to-business return systems, and that the reuse of parts is notified to the consumer. Expired on 5 November 2017
31a Lead, cadmium, hexavalent chromium, and polybrominated diphenyl ethers (PBDE) in spare parts recovered from and used for the repair or refurbishment of medical devices, including in vitro diagnostic medical devices, or electron microscopes and their accessories, provided that the reuse takes place in auditable closed-loop business-to-business return systems and that each reuse of parts is notified to the customer.  Applies to categories 8 and 9. Expires on: — 21 July 2024 for category 9 (industrial monitoring and control instruments).
32 Lead in solders on printed circuit boards of detectors and data acquisition units for Positron Emission Tomographs which are integrated into Magnetic Resonance Imaging equipment. Expired on 31 December 2019
33 Lead in solders on populated printed circuit boards used in Directive 93/42/EEC class IIa and IIb mobile medical devices other than portable emergency defibrillators. Expried on 30 June 2016 for class IIa and 31 December 2020 for class IIb.
34 Lead as an activator in the fluorescent powder of discharge lamps when used for extracorporeal photopheresis lamps containing BSP (BaSi2O5:Pb) phosphors.  Expired on 22 July 2021.
35 Mercury in cold cathode fluorescent lamps for back-lighting liquid crystal displays, not exceeding 5 mg per lamp, used in industrial monitoring and control instruments placed on the market before 22 July 2017.  Applies to category 9 (industrial monitoring and control instruments). Expires on 21 July 2024.
36 Lead used in other than C-press compliant pin connector systems for industrial monitoring and control instruments. Expired on 31 December 2020.
37 Lead in platinized platinum electrodes used for conductivity measurements where at least one of the following conditions applies: (a) wide-range measurements with a conductivity range covering more than 1 order of magnitude (e.g. range between 0,1 mS/m and 5 mS/m) in laboratory applications for unknown concentrations; (b) measurements of solutions where an accuracy of +/C 1 % of the sample range and where high corrosion resistance of the electrode are required for any of the following: (i) solutions with an acidity < pH 1; (ii) solutions with an alkalinity > pH 13; (iii) corrosive solutions containing halogen gas; (c) measurements of conductivities above 100 mS/m that must be performed with portable instruments. Applies to categories 8 and 9.
Expires on 31 December 2025.
38 Lead in solder in one interface of large area stacked die elements with more than 500 interconnects per interface which are used in X-ray detectors of computed tomography and X-ray systems. Expired on 31 December 2019.
39 Lead in micro-channel plates (MCPs) used in equipment where at least one of the following properties is present: (a) a compact size of the detector for electrons or ions, where the space for the detector is limited to a maximum of 3 mm/MCP (detector thickness + space for installation of the MCP), a maximum of 6 mm in total, and an alternative design yielding more space for the detector is scientifically and technically impracticable; (b) a two-dimensional spatial resolution for detecting electrons or ions, where at least one of the following applies: (i) a response time shorter than 25 ns; (ii) a sample detection area larger than 149 mm2; (iii) a multiplication factor larger than 1,3 × 103. (c) a response time shorter than 5 ns for detecting electrons or ions; (d) a sample detection area larger than 314 mm2 for detecting electrons or ions;(e)a multiplication factor larger than 4,0 × 107. Applies to categories 8 and 9.
40 Lead in dielectric ceramic in capacitors for a rated voltage of less than 125 V AC or 250 V DC for industrial monitoring and control instruments. Expired on 31 December 2020
41 Lead as a thermal stabiliser in polyvinyl chloride (PVC) used as base material in amperometric, potentiometric and conductometric electrochemical sensors which are used in in-vitro diagnostic medical devices for the analysis of blood and other body fluids and body gases.  Applies to category 8 (in vitro diagnostic medical devices)
Expires on 31 March 2022
42 Mercury in electric rotating connectors used in intravascular ultrasound imaging systems capable of high operating frequency (> 50MHz) modes of operation. Applies to categories 8 (other than in vitro diagnostic medical devices) and 9 (other than industrial monitoring and control instruments).
Expires on 30 June 2026
43 Cadmium anodes in Hersch cells for oxygen sensors used in industrial monitoring and control instruments, where sensitivity below 10 ppm is required. Applies to category 9 (industrial monitoring and control instruments).
Expires on 15 July 2023
44 Cadmium in radiation tolerant video camera tubes designed for cameras with a centre resolution greater than 450 TV lines which are used in environments with ionising radiation exposure exceeding 100 Gy/hour and a total dose in excess of 100kGy. Applies to category 8 (other than in vitro diagnostic medical devices) and 9.
Expires on 31 March 2027
* Note: These are simplified lists. Enviropass Expertise Inc. does not warrant the accuracy or completeness of these documents. The opinion expressed in this document is only that of the Enviropass Expertise Inc and does not constitute legal advice. Technical and compliance specifications and any other materials or information provided are subject to change without notice and reliance on its contents shall be at your sole risk.

Enviropass maintains the updated RoHS exemptions lists on the Europe RoHS page.

RoHS Exemptions Differ from a Product Category to Another

As you can see in the tables above, the exemption scope differs depending on the electrical or electronic equipment category. Here is a table with the different product categories per Annex I of EU RoHS:

Category # Products Scope
1 Large household appliances
2 Small household appliances
3 IT and telecommunications equipment
4 Consumer equipment
5 Lighting equipment
6 Electrical and electronic tools
7 Toys, leisure and sports equipment
8 Medical devices
9 Monitoring and control instruments including industrial monitoring and control instruments
10 Automatic dispensers
11 Other EEE not covered by any of the categories above
RoHS product categories 1 to 11

The exemption scope can apply only to a portion product category, like in vitro diagnostic medical devices (part of category 8) or industrial monitoring and control instruments (part of category 9).

 

Annex III of Directive 2011/65/EU lists general exemptions. Product categories 1 to 7 and 10 typically share the same exemptions. 

 

 

Some particular exemptions rule apply to categories 8 and 9, and 11. Even within category 8, in-vitro medical devices benefit from some special provisions. In category 9, industrial monitoring and control instruments also have extensions or more access to exemptions.

 

Additionally, Annex IV of Directive 2011/65/EU gives exemptions to categories 8 and 9.

Why RoHS Exemptions?

RoHS exemption Access to markets

RoHS is an EU Directive that restricts the use of certain hazardous substances in electrical and electronic equipment. For technical reasons, some applications benefit from exemptions to the general restriction limits. However, as technology improvements tend to reduce environmental impacts, several RoHS exemptions will eventually vanish.

 

To push improvements from the industry, article 5 of the Directive 2011/65/EU requires the European Union to revise the Annex III list of exemptions at least every five years, from July 2011. As a result, on July 22nd, 2021, the European Union updated the entire Annex III RoHS exemption list.

 

Exemptions were either:

  • Renewed and maintained when there is no viable technological alternative on the market;
  • Modified, typically with additional constraints; or
  • Removed

Expired RoHS Exemptions on July 21st, 2021

Expired RoHS exemptions

Several exemptions have expired on July 21st, 2021. 

For example: 

  • General exemptions 21a, b, and c for particular cadmium and lead applications in printing inks;
  • Specific lead exemption 34 in the fluorescent powder of discharge lamps in some medical devices, monitoring and control instruments

 

Manufacturers or Electrical or electronic products can no longer claim these exemptions. Instead, they must revise their technical file and eventually the parts lists to avoid parts using expired exemptions.

Maintained RoHS Exemptions

Renewed RoHS Exemptions

The European Commission maintained most exemptions for another period validity of 5 years. It is the case for example of these common exemptions in electronic products:

  • Exemption 6A1 applicable to lead in certain steel alloys;
  • Exemptions 7C1 and 7C2 for lead in some galls or ceramic applications.

It is important to note that many exemptions apply to fewer product categories than before. For instance, some only apply to products categories 8, 9, and 11.

What to do to Comply with the Current RoHS Exemption list?

Monitoring RoHS exemptions

Manufacturers should update their technical files and see what parts in the product's bills of materials (BOMs) no longer comply. Then, they must find valid alternatives on the market with RoHS exemptions. Maintaining the RoHS technical file is essential. An internal procedure should detail how to do it.

 

To audit your suppliers, you can use the free Enviropass Product Environmental Compliance (EPEC) form. The EPEC form keeps up with the valid RoHS exemptions.

Unsure about the EU RoHS exemptions in your products? Ask an Enviropass specialist!

Enviropass Expertise Inc. 

Tel: +1 (514) 887-7871

Email: Contact@getenviropass.com