RoHS Exemptions & Extensions: Is Your Program Impacted?

RoHS Exemptions & Extensions: Is Your Program Impacted?

January 21, 2021 — the date when a number of Restriction of Hazardous Substances (RoHS) Directive exemptions are scheduled to expire — still seems a long way away.

But when you factor in the January 2020 deadline to submit exemption extension requests, and consider the documentation that needs to be created in order to apply for an extension, that date suddenly seems just around the corner.

The majority of the 46 RoHS exemptions that expired on July 21, 2016, were recommended for five-year extensions, with the Oeko Institut suggesting a July 21, 2021, expiration date for exemptions applying to Categories 1 to 7 and 10.

Don’t get caught off guard by expiring RoHS exemptions. For more information, read our whitepaper, European Union RoHS Directive: Understanding Exemptions.

At present, there are approximately 30 extensions pending review and approval by the European Commission, but companies must remember the 18-month window required to submit extension requests.  

In order to request an extension, a company must provide the required documentation, which includes technical and waste information, along with substitution availability and substance removal plans. In order to compile the necessary paperwork by the January 2020 deadline, companies are advised to begin gathering the information they need now. Even if the European Commission has not determined that an extension will expire, companies should operate under the assumption that it will to ensure they are prepared.

For example, some of these expirations will impact companies that use cadmium, which is found in products such as electrical contacts, printing inks and enamel on glass. Glass itself will also no longer be able to contain cadmium or lead if the applicable exemption is not renewed.

Last month, the European Commission extended nine expired exemptions and added seven new exemptions. Six of the seven new exemptions put further restrictions in place for specific categories. Meanwhile, the organization incorporated one brand new exemption (Exemption 42), which applies only to Category 11 (all other electrical and electronic equipment) and comes into effect on July 22, 2019.

It’s important for companies to properly manage product compliance data to evaluate RoHS exemptions and exemption expiration dates. To learn more about how Assent’s RoHS Module can streamline your supply chain data collection and reporting processes, email