The European Commission received 87 RoHS Annex III exemption renewal requests before the January 21, 2015 deadline. Most of the renewal requests were based on proposals developed by industry association working groups. The exemptions will expire on July 21, 2016 for most products unless the renewal applications are successful. For some exemptions, multiple renewal requests were submitted by different stakeholders. The requests will be put through the review and stakeholder consultation over the coming months to determine whether the renewals are justified according to the criteria specified in the Directive.
For most of the renewal requests, the proposal is to simply renew the existing wording of the exemption; for a few exemptions, modified wording is proposed. The Annex III exemptions that are due for expiry and have no exemption renewal request (as of January 21, 2015) are listed in Table 2.
Table 2: Exemptions with no renewal request by January 21, 2015
| Index | Title |
|---|---|
| 2(b)(2) | Mercury in other fluorescent lamps not exceeding (per lamp):Non-linear halophosphate lamps (all diameters): 15 mg |
| 5(a) | Lead in glass of cathode ray tubes |
| 17 | Lead halide as radiant agent in high intensity discharge (HID) lamps used for professional reprography applications |
| 25 | Lead oxide in surface conduction electron emitter displays (SED) used in structural elements, notably in the seal frit and frit ring |
| 30 | Cadmium alloys as electrical/mechanical solder joints to electrical conductors located directly on the voice coil in transducers used in high-powered loudspeakers with sound pressure levels of 100 dB (A) and more |
| 31 | Lead in soldering materials in mercury free flat fluorescent lamps (which e.g. are used for liquid crystal displays, design or industrial lighting) |
| 33 | Lead in solders for the soldering of thin copper wires of 100 micrometer diameter and less in power transformers |
| 38 | Cadmium and cadmium oxide in thick film pastes used on aluminium bonded beryllium oxide |
Four renewal requests received by the Commission are already underway and the public consultation is scheduled to begin in March. A summary of the renewal requests and the project is available on the project website. The project (referred to as Pack 7) is expected to complete in September 2015.
Impact on Manufacturers
If the renewal of an Annex III exemption that you are currently using is not successful or if the scope of the exemption is narrowed whereby your products/applications are no longer covered, the expiry may have a significant technical and business impact on your organization. If the expired exemption was used by your suppliers, the suppliers may need to design out the restricted substance. However, given the R&D investment to do so, some suppliers may discontinue parts that do not have sufficient business justification. If parts are discontinued, then OEMs will need to identify and qualify substitutes.
If the restricted substance is directly specified by your organization (for example in a material specified on a mechanical drawing or during manufacturing operations); then redesign will be necessary to eliminate the restricted substance.
Regardless of whether the exemption is used by a supplier or in your product design specifications, your organization will need to update its RoHS technical documentation file to demonstrate that the exemption is no longer being used.
Updates
The renewal request for exemption 7(b) was withdrawn on April 9, 2015. See blog article RoHS Exemption 7(b) Renewal Request is Withdrawn