EU RoHS Exemption List

The European Union restricts the use of certain hazardous substances in electrical and electronic equipment in the RoHS Directive 2011/65/EU. However, RoHS contains EU RoHS exemption list in Annexes III and IV of its Directive.

Significantly, such lists are constantly evolving as technology advances. You can read about some of the past updated RoHS exemption lists in this article.

EU RoHS Exemption List

In 2021, the EU put nine exemptions under review for an expiry date extension.

Since then, other exemption amendments apply. Here are the current updated lists of EU RoHS exemptions.

Updated RoHS Exemptions 6 family - 6(a) – Annex III

Lead as an alloying ingredient in steel for machining
Lead in galvanized steel containing up to 0.35 percent lead by weight.

Exemption 6(a)-I – Annex III

Lead as an alloying element in steel for machining purposes containing up to 0.35 % lead by weight
Lead in batch hot-dip galvanized steel components containing up to 0.2 % lead by weight.

Exemption 6(b) – Annex III

Lead as an alloying element in aluminum containing up to 0.4 % lead by weight.

Exemption 6(b)-I – Annex III

Lead as an alloying element in aluminum containing up to 0.4 % lead by weight provided it stems from lead-bearing aluminum scrap recycling.

Exemption 6(b)-II – Annex III

Lead as an alloying element in aluminum for machining purposes with a lead content of up to 0.4 % by weight.

Exemption 6(c) – Annex III

Copper alloys containing up to 4 percent lead by weight.

Updated RoHS Exemptions 7 family - Exemption 7(a) – Annex III

Lead in high melting temperature type solders.

Exemption 7(c)-I – Annex III

For components containing lead in a glass or ceramic other than dielectric ceramic in capacitors or in a glass or ceramic matrix compound.

Exemption 7(c)-II – Annex III

Lead within dielectric ceramic in capacitors with 125 V AC or 250 V DC or higher.

Updated RoHS Exemptions and the Öko-Institut

The Öko-Institut launched an investigation to gather data regarding the above exemptions and released its report on January 13th, 2022. As of late the Öko-Institut has only published recommendations, but Enviropass recommends that manufacturers and suppliers monitor these exemptions for updates.

Updated RoHS Exemptions

Recently, the European Commission issued RoHS amendments to update the list of exemptions. They added or extended the expiry dates of a few exemptions in Annexes III and IV effective as of March 25th, 2020.

EU RoHS Exemption List with Example of Exemptions

Exemption	Amendment	Description	Update(s)
9, 9(a)I, 9(a)-II Annex III	Directive (EU) 2020/361	In absorption refrigerators, hexavalent chromium (Cr) as an anticorrosion agent can be present up to 0.75 percent by weight of the carbon steel cooling system	Exemption 9 from 2011/65/EU split into 9, 9(a)I, 9(a)-II The expiry dates are according to different categories
41 Annex III	Directive (EU) 2020/365	For solders and termination finishes used in some hand-held combustion engines containing lead (Pb).	Exemption renewed The expiry dates are now according to different categories
37 Annex IV	Directive (EU) 2020/360	For lead (Pb) in platinized platinum electrodes used for specific conductivity data.	Exemption renewed Change in expiry dates
41 Annex IV	Directive (EU) 2020/366	For lead (Pb) utilized as a thermal stabilizer in polyvinyl chloride, which is employed in various in-vitro diagnostic medical devices that analyze blood and other bodily fluids and gases.	Exemption renewed Change in expiry dates
44 Annex IV	Directive (EU) 2020/364	For certain radiation-tolerant video camera tubes containing cadmium (Cd).	New exemption

Updated RoHS Exemptions 9 family

The amendment states that, this exemption applies to “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”.

The categories in question are categories 8, 9, and 11.

As for when this exemption will expire, for categories 8 and 9 that don’t fall into in-vitro diagnostic medical devices or industrial monitoring and control instruments, the expiry is July 21st, 2021.

For category 8 in-vitro diagnostic medical devices, the expiry is July 21st, 2023.

Lastly, for category 9 industrial monitoring and control instruments and category 11, the expiry is July 21st, 2024.

Exemption 9(a)-I

The amendment states that this exemption allows “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 utilized power input < 75 W at constant running conditions”.

The categories in question are categories 1 through 7 as well as 10.

As for the expiry, March 5, 2021, marks the end for all categories.

Exemption 9(a)-II

The stated entry allows “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” and that for refrigerators “designed to operate fully or partly with electrical heater, having an average utilized power input ≥ 75 W at constant running conditions” and for refrigerators “designed to fully operate with non-electrical heater”.

The categories in question are categories 1 through 7 as well as 10.

Furthermore, July 21st, 2021, marks the expiry for all categories.

Renews Exemption 41 - 2011/65/EU of Annex III

The amendment renewed the original exemption 41 of Annex III and changed the expiry dates as follows:

Categories 1 through 7 as well as 10 expire on March 31st, 2022.
Categories 8 and 9 that don’t fall into in-vitro diagnostic medical devices or industrial monitoring and control instruments, expire on July 21st, 2021.
Category 8, in vitro diagnostic medical device instruments, expires on July 21st, 2023.
Lastly, category 9, industrial monitoring and control instruments, expires on July 21st, 2024.

Renews Exemption 37 - 2011/65/EU of Annex IV

The amendment renewed the original exemption 37 of Annex IV and extended the expiry date to December 31st, 2025.

Renews Exemption 41 - 2011/65/EU of Annex IV

The amendment renewed the original exemption 41 of Annex IV and extended the expiry date to March 31st, 2022.

Exemption 44 – New Exemption of Annex IV

As the amendment states, exemption 44 applies to “Cadmium in radiation-tolerant video camera tubes designed for cameras with a center resolution greater than 450 TV lines used in environments with ionizing radiation exposure exceeding 100 Gy/hour and a total dose exceeding 100kGy”.

This applies to category 9 electronics and expires on March 31st, 2027.

EU RoHS Exemption List: 2017

The European Commission updated the list of EU RoHS exemptions in March 2017 and created four new exemptions, with expiry dates: 9b-I, 13b-I, 13b-II, and 13b-III. Moreover, they added exemptions 9b, 13a, and 13b.

La liste des exemptions de RoHS Europe a été mise à jour en mars 2017 par la Commission européenne. 4 nouvelles exemptions avec des dates d’expiration ont été créées : 9b-I, 13b-I, 13b-II et 13b-III. De plus, des dates d’expirations ont été ajoutées aux exemptions 9b, 13a et 13b.

Enviropass maintains the updated list.

La liste à jour est maintenue par Enviropass.