Study to assess requests for renewal of five (-5-) exemptions under 2(b)(4)-I, 4(f)-I, 45 of Annex III and 42, 49 of Annex IV, and for a revocation of one (-1-) exemption under 14 of Annex IV to the Directive 2011/65/EU - Pack 28

Directive 2011/65/EU1 (RoHS Directive) restricts the use of certain hazardous substances in electrical and electronic equipment. The RoHS Directive is regularly updated according to scientific and technical progress. The adaptation to scientific and technical progress is reflected in the lists of specific exemptions from the substance restrictions, in Annexes III and IV to the RoHS Directive.

Any adaptation of the Annexes allowing a limited use of hazardous substances by means of exemption needs to follow specific requirements set by the Directive. In particular, Article 5(1)(a) provides that the Commission may adopt measures to adapt Annexes III and IV in order to exempt materials and components from the RoHS substance restrictions, provided that this does not compromise the environmental and health protection objectives of Regulation (EC) No 1907/2006 and that one of the specific conditions is met:

The decision on inclusion of materials and components of EEE in Annexes III and IV on exemptions and on the duration of possible exemptions shall take into account the availability of substitutes and the socio-economic impact of substitution. Decisions on the duration of possible exemptions shall take into account any potential adverse impacts on innovation. Life-cycle thinking on the overall impacts of the exemption shall apply, where relevant.

Based on these provisions, the Commission is receiving requests for (granting, renewing, or revoking) exemptions that need to be evaluated in order to assess whether these requests fulfil the requirements of Article 5(1). Where the requirements of Article 5(1) are met, the Commission shall adopt a measure (delegated directive) amending the respective Annex to the RoHS Directive. This project was conducted as part of a specific contract n° 090202/2025/4500085903/ENV.B3 from the European Commission. The purpose of the mandate, within the context of a framework contract, was to assess five exemptions for renewal and one for revocation to be included in or deleted from Annexes III and IV of the RoHS Directive 2011/65/EU.