Free of Charge: RoHS Exemptions Webinar and Discussion - Last Status

On January 13, 2025, the European Commission released draft delegated directives proposing the revocation and renewal of critical Restriction of Hazardous Substances (RoHS) exemptions concerning the use of lead in various applications (from exemption pack 22):

• Lead as an alloying element in steel, aluminum, and copper: Exemptions 6(a), 6(a)-I, 6(b), 6(b)-I, 6(b)-II, 6(c)
• Lead in high-melting-temperature solder: Exemption 7(a)
• Lead in glass or ceramic: Exemptions 6(a), 6(a)-I, 6(b), 6(b)-I, 6(b)-II, 6(c)

We would like to invite you free of charge Webinar to update you about the status in English Language.

✨ Participation fees: Free of Charge ✨

📅 Date:

Thursday, January 30, 2025, from 16:00 to 17:00 (European Central Time).

To register, please, use this form “Only Business Emails are accepted”:

https://events.teams.microsoft.com/event/b728b319-0848-4122-a8ce-92faa1a745fb@a153da80-648d-4170-8cec-1435f54a8376

These proposals are open for public consultation until February 10, 2025, providing four weeks for industry stakeholders to respond to the suggested expiration dates and subdivision of exemptions. Companies operating in or supplying to the European Economic Area (EEA) are advised to promptly assess their reliance on these exemptions, determine if lead-containing parts are used, and evaluate the necessity of extending these exemptions. The window for renewal applications or identifying lead-free alternatives is notably short.

The proposed changes are expected to significantly impact global manufacturing supply chains due to the shorter-than-anticipated regulatory timelines. Let’s examine these updates in detail.

Proposed RoHS Exemption Expirations & Revocations

The latest regulatory updates, characterized by unusually brief validity periods, have caught compliance professionals off guard. Specific exemptions are proposed for revocation or expiration within the following timelines:

Revocations (Phase-out period: 12–18 months):

• 6(a): Lead as an alloying element in steel for machining purposes and galvanized steel (up to 0.35% lead by weight).
• 6(b): Lead as an alloying element in aluminum (up to 0.4% lead by weight).
• 6(b)-I: Lead in aluminum (up to 0.4% lead by weight) derived from lead-bearing aluminum scrap recycling (equipment categories 1–7 and 10).
• 6(b)-II: Lead in aluminum for machining purposes (up to 0.4% lead by weight) (equipment categories 1–7 and 10).

Proposed Expirations by December 31, 2026:

• 6(a)-I: Lead in steel for machining purposes (up to 0.35% lead by weight).
• 6(a)-II: Lead in batch hot-dip galvanized steel components (up to 0.2% lead by weight).
• 6(b)-I: Lead in aluminum from recycled scrap (up to 0.4% lead by weight) (categories 9 IMCI and 11).
• 6(b)-II: Lead in aluminum for machining purposes (up to 0.4% lead by weight) (categories 9 IMCI and 11).
• 6(b)-III: Lead in aluminum casting alloys (up to 0.3% lead by weight) from recycled scrap (new exemption).
• 6(c): Copper alloy (up to 4% lead by weight).
• 7(a): Lead in high-melting-temperature type solders (lead-based alloys containing ≥85% lead by weight).
• 7(c)-I: Lead in glass or ceramics used in electrical components (excluding dielectric ceramic in capacitors).

Proposed Expirations by December 31, 2027:

• 7(a)-I to VII: Specific uses of lead in high-melting-temperature solders (new exemptions).
• 7(c)-II: Lead in dielectric ceramics for capacitors (rated ≥125V AC or 250V DC).
• 7(c)-V: Lead in glass for specific functions (new exemption).
• 7(c)-VI: Lead in ceramics for specific applications, including:
• Piezoelectric lead zirconium titanate (PZT) ceramics.
• Ceramics with a positive temperature coefficient (PTC).

RoHS Compliance Action Plan

At ComplyMarket, we are committed to protecting our customers’ business interests in the EU by taking the following actions:

1. Feedback Submission: We will gather input from our customers and present comprehensive feedback to the European Commission’s proposal.
2. Extension Application: We will file applications to extend the necessary exemptions, ensuring continued compliance and supply chain stability for our customers.

If you want ComplyMarket to represent your company in the European Commission for RoHS Exemptions and send the extension application on your behalf, please, pay the required fees using this link or ask us for an invoice

https://buy.stripe.com/eVa6oq1qwba44eI9AS

Given the far-reaching implications and compressed timeline, immediate action is essential to mitigate potential disruptions.

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Thank you for your attention, and we hope to see you there!

Best regards/Mit freundlichen Grüßen,

ComplyMarket Team

Anna Witzmann

ComplyMarket UG (haftungsbeschränkt)

Email:  complymarket@complymarket.com

Tel. +491637819457

44 Tal, 80331

Munich, Germany

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