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RoHS exemption 45 - Initiator of explosives

The European Union published a new amendment to the EU RoHS directive 2011/65/EU. It is the Commission Delegated Directive (EU) 2021/647 regarding a RoHS lead exemption for electric and electronic initiators of explosives for civil purposes.

What are the Exempted Substances?

RoHS restricts ten groups of substances. Lead and lead compounds are one of them. Since various applications require lead without easy replacements, the European Commission maintains and regularly revisits a list of RoHS exemptions.

This exemption No. 45 only covers the following hexavalent chromium and lead compounds:

  • Barium chromate – CAS # 10294-40-3
  • Lead diazide – CAS # 13424-46-9
  • Lead dioxide – CAS # 1309-60-0
  • Lead dipicramate
  • Lead styphnate – CAS # 15245-44-0
  • Orange lead (lead tetroxide) – CAS # 1314-41-6

What Product Categories are Impacted?

The RoHS exemption 45 applies to the products of category 11 – electronic and electrical equipment not covered under other EU RoHS product categories. The electric and electronic initiators of explosives for civil (professional) use can benefit from this exemption.

Quarries - RoHS exemption 45

Applications include:

  • Detonators,
  • Electric fuse heads,
  • Primary explosive charges,
  • Pyrotechnic delay charges,
  • Integrated rescue systems.


  • pyrotechnic, 
  • quarries, 
  • mines, 
  • construction, or 
  • demolition activities.

When does the RoHS Lead Exemption 45 come into Force?

This exemption applies as of November 1st, 2021. It expires on April 20th, 2026, by default, unless extended. 

How to Comply with EU RoHS and the List of RoHS Lead Exemptions?

There are various options. However, for complex products with several homogeneous materials, it is recommended to audit your supply chain and compile a technical file, following standard IEC 63000

Enviropass has designed the free EPEC (Enviropass Product Environmental Compliance) form to help you gather RoHS details from your supply chain. Enviropass has updated the EPEC form with exemption 45.

Any questions on the EU RoHS exemptions and how to comply with RoHS, ask an Enviropass expert and get online training!