EU RoHS Exemptions Expired, Extended & Updated

EU RoHS Exemptions Expired, Extended & Updated

This July has seen several significant changes to the EU Restriction of Hazardous Substances (RoHS) Directive. Several exemptions to the EU RoHS Directive have expired while others have been extended or are now subject to further scrutiny.

Additionally, on July 22, 2019, four phthalates were restricted and Category 11 products came into scope. With all these updates and changes, it’s more important than ever for in-scope companies to ensure they’re still compliant with RoHS.

What’s Changed?

Several exemptions were granted extensions as previously announced, but some received further restrictions. Categories 1 through 7 and 10 saw some of the most significant changes as a result of these additional restrictions. Most of these exemptions impact steel and aluminum products that include lead as an alloying element.

Exemptions 6(a)-I, 6(b)-I and 6(b)-II still apply for categories 1 through 7 and 10, but the specifics have been updated:

  • For 6(a)-I, lead can still be used as an alloying element in steel for machining purposes, but can only contain up to 0.35 percent lead by weight. In batch hot dip galvanized steel components, the limit is now 0.2 percent lead by weight.
  • Under 6(b)-I, aluminum products that use lead as an alloying element may only contain up to 0.4 percent lead by weight; even then, the lead content must be sourced from recycled aluminum scrap.
  • Finally, for 6(b)-II, lead used as an alloying element in aluminum for machining purposes can contain up to 0.4 percent lead by weight.

Meanwhile, exemptions 6(a) and 6(b) continue for categories 8, 9 and 11 only (medical devices, monitoring and control instruments, and other electrical and electronic equipment, respectively). Under 6(a), steel for machining purposes and galvanized steel can use lead as an alloying element, up to a total of 0.35 percent lead by weight. Under (6b), aluminum can also use lead as an alloying element, and can contain up to 0.4 percent lead by weight.

What Is an Exemption?

Exemptions temporarily allow manufacturers to use a restricted substance for a certain application until an alternative substance is available. Under the EU RoHS Directive, exemptions to the regulation apply to both substances and specific applications. All RoHS exemptions expire within a set amount of time, but they are frequently extended or amended based on market feedback and the reliability of proposed replacement substances, usually as a result of a supplier application for an extension.

Ensuring Supplier Exemptions Are Up-To-Date

While these changes aren’t drastic or completely unexpected given the exemption process, they do present a potential risk for companies that previously claimed these exemptions. These companies should take the time to conduct a materials-based risk assessment to ensure their products are within the specified limits of lead by weight content.

Furthermore, for companies with suppliers claiming the 6(a) and 6(b) exemptions, it’s important to make sure suppliers are claiming the up-to-date exemptions when applying. The Assent Compliance Platform can help companies ensure they are claiming the correct exemptions.

To learn how our Product Compliance Suite can streamline your supply chain data collection and reporting processes, email