5th Feb 2016
Under Article 5 of RoHS2, manufacturers may submit applications for exemptions listed in Annexes III and IV. These may only be included if substitution of the material or application in which the restricted substance is used is scientifically or technically impracticable; the reliability of a substitute is not ensured or the negative environmental, health and consumer safety impacts of substitution outweigh the benefits thereof.
Following applications by Emerson Climate Technologies and Spectaris, the Oeko-Institut and Fraunhofer Institute IZM carried out an eight week stakeholder consultation and evaluation of the exemption requests. The study assessed the duration needed for the exemptions, the availability of substitutes and the socio-economic impact of substitution, as well as adverse impacts on innovation, and life cycle analysis concerning the overall impacts of the exemption.
The study concluded that exemption 9b was justifiable due to uncertainties regarding the reliability of certain substitutes and 13a and 13b were justifiable due to the lack of suitable alternatives. It recommended that RoHS2 be amended with the following exemptions and expiry dates:
Exemption number | Exemption |
Expiry date |
---|---|---|
9(b) |
Lead in bearing shells and bushes for refrigerant-containing hermetic scroll compressors with a stated electrical power input equal or below 9kW for heating, ventilation, air conditioning and refrigeration (HVACR) applications |
21 July 2019 |
13(a) |
Lead in white glasses used for optical applications |
21 July 2021; in-vitro medical devices 21 July 2023; industrial monitoring and control instruments 21 July 2024 |
13(b) |
Lead in ion coloured optical filter glass types, or cadmium in striking optical filter glass types or lead and cadmium in glazes used for reflectance standards – excluding applications falling under Ex. point 39 of Annex III |
21 July 2021 |
Cadmium and lead in filter glasses and glasses used for reflectance standards |
21 July 2021; in-vitro medical devices 21 July 2023; industrial monitoring and control instruments 21 July 2024 |
The European Commission will now consider these recommendations and amend RoHS2 as appropriate.
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