EU RoHS Directive: Review of Exemptions
ENFORCEMENT TIMELINE
Ongoing technical review (evaluation transitioning to ECHA in 2025–2026)
Overview
Exemptions set out in Annexes III and IV of the EU RoHS Directive (2011/65/EU) permit continued use of certain restricted substances only where no viable alternative technology exists. These exemptions are periodically reviewed and are progressively narrowed or allowed to expire once substitutes become technically feasible.
As part of its ongoing evaluation and revision process, the European Commission is transferring the scientific and technical assessment of exemptions to the European Chemicals Agency (ECHA), tightening scrutiny and improving transparency.
Enforcement Timeline
Ongoing renewal process: operators must submit renewal applications at least 18 months before an exemption's expiry date.
2024–2025: Publication of major exemption evaluation reports (such as Pack 22 and Pack 23) and their adoption by the European Commission.
2026: ECHA's centralized RoHS exemption review system becomes fully operational.
Business Impact
Manufacturers of electrical and electronic equipment need to track the expiry and renewal status of exemptions they rely on (such as those covering lead, mercury, and hexavalent chromium) and prepare alternative-design roadmaps in advance of any exemption's expiry.