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EU RoHS GuideEU

EU RoHS Directive Exemptions Tracking

RoHS exemptions are temporary, application-specific exceptions in Annex III and Annex IV for materials and components of electrical and electronic equipment.

This page helps structure a register for exemption scope, category coverage, expiry dates, renewal status, substitution evidence, and technical-file records.

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Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
4 sections4 primary sources
Overview

Track every relied-on so an old Annex III or Annex IV entry is not treated as permanent clearance. The register should tie the exemption to the exact material or component, category, expiry or renewal status, Article 5 justification, substitution evidence, and technical documentation used for market placement.

Section 1

Build the exemption register around the Annex entry

Track RoHS exemptions at the level where the legal exception is written: the specific material or component, its use, the restricted substance, the covered category, and the Annex III or Annex IV entry. Annex III entries may cover one or more EEE categories; Annex IV is limited to applications specific to medical devices and monitoring and control instruments.

Do not store an exemption as a generic product approval. The register should show why that entry applies to the or component in the marketed product and where the supporting declaration, supplier statement, test evidence, or engineering assessment sits in the technical file. It should also identify the current consolidated Annex or delegated act used for the legal-status check.

Use the current Annex wording as a matching test. For example, Annex III now separates several lead-in-steel, lead-in-aluminium, copper-alloy, and high-melting-temperature-solder uses into entries with different composition limits, technical conditions, category coverage, and dates. A register row that says only '6(a)' or '7(a)' can miss a successor entry or narrowed condition.

  • Record the Annex entry number, Annex III or Annex IV, exact wording, restricted substance, material or component, specific application, product family, category, and affected stock-keeping units (SKUs).
  • Separate new exemption reliance from renewal monitoring and revocation monitoring because Article 5 treats granting, renewing, and revoking exemptions as separate application paths.
  • Flag any entry where the Annex wording, product category, component use, or supplier material declaration does not match cleanly; those cases need regulatory review before release.
  • Distinguish legal sources from process material: an adopted delegated act and the current Annex can establish an exemption, while an application, consultation, assessment report, draft act, or supplier declaration cannot.
  • Give each row a release effect: allowed use with complete evidence; allowed use while a timely renewal remains pending; blocked because legal or engineering fit is unresolved; blocked because the entry expired; or substitution required because no exemption applies.
Section 2

Track expiry, renewal, and Commission decision status

Each exemption row needs a live status supported by more than an expiry date copied from an Annex. Under RoHS Article 5, new exemptions have validity periods decided case by case, up to five years for categories 1 to 7, 10 and 11 and up to seven years for categories 8 and 9. Renewal applications must be made no later than 18 months before expiry.

The Commission states that exemption decisions currently take 18 to 24 months from the application date. A timely renewal request keeps the existing exemption valid until the Commission decides; if renewal is rejected or an exemption is revoked, the expiry occurs 12 to 18 months after the decision. A pending request for a new exemption has no equivalent market-placement effect.

  • Use status values such as active, renewal submitted on time, under Commission assessment, renewed with new expiry, rejected with transition period, revoked with transition period, expired, or replacement needed. As an operational control, assign a regulatory reviewer to approve each status against the dated legal entry, renewal acknowledgement, or adopted decision; procurement supplies part evidence and engineering confirms the application match.
  • Store the renewal trigger date, application-submission evidence, the Commission acknowledgement due within 15 days, the decision timeline due within one month, public consultation or assessment-study reference, and final delegated directive reference where available.
  • Escalate any exemption that has no timely renewal application, has a past Annex expiry date with no documented renewal status, or is being used for a category or application outside the Annex wording.
Section 3

Evidence fields that make the register reviewable

A record should explain both the legal fit and the engineering fit. Annex V requires exemption applications to identify the material or component, specific substance uses, verifiable justification under Article 5, alternatives analysis on a lifecycle basis where available, reuse or recycling information, proposed alternative-development actions and timing, proprietary-information justification where needed, proposed exemption wording, and an application summary.

For products already relying on an exemption, use the same evidence structure internally. It gives procurement, quality, engineering, and regulatory teams a shared file for supplier changes, technical-file updates, and release decisions.

  • Evidence fields: bill-of-materials (BOM) line, supplier part, , restricted substance, concentration evidence, Annex entry, category, product use, market-placement rationale, and technical-file location.
  • Substitution fields: available alternatives, reliability concerns, design-change assessment, lifecycle impacts where available, socioeconomic notes, innovation-impact notes, and planned actions to develop or apply alternatives.
  • Governance fields: accountable owner, reviewer, last review date, next legal-status check, renewal trigger date, application filing date, decision status, unresolved data gaps, confidential-information basis, and release blocker or allowed-use decision.
  • Source fields: current Annex text, amending delegated act, Commission application or renewal acknowledgement, assessment or consultation reference, final decision date, transition end date, and a saved copy or stable link for each status change.
Recommended next step

Review RoHS exemption reliance before release

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Section 4

Common exemption-tracking failure modes

Treating an exemption as permanent or product-wide breaks the control. RoHS exemptions are limited in time, tied to Annex wording, and reassessed against substitutes, impacts, socioeconomic factors, and innovation effects. A product release should not rely on an exemption unless the row still matches the material, component, category, application, and timing.

Another failure is confusing an application for a new exemption with permission to place non-compliant on the market. The Commission implementation page states that after submitting a request for a new exemption, equipment must still comply with the Directive until the Commission adopts a decision granting the exemption.

  • Do not reuse an Annex entry without checking category-specific expiry dates, split entries, and narrowed wording introduced by delegated directives.
  • Do not rely on renewal status unless the register stores the filing date or Commission-process evidence that keeps the existing exemption valid during review.
  • Do not let supplier declarations replace the alternatives and substitution evidence needed for an exemption rationale or renewal decision.
  • Recheck the row at product release and after a BOM revision, supplier or material change, category change, new delegated act, Commission renewal decision, exemption expiry, non-conformity, or authority request.
Primary sources

References and citations

Directive 2011/65/EU on restriction of hazardous substances (RoHS)
eur-lex.europa.eu5 citations
Referenced sections
  • Current binding RoHS text as of 1 July 2026 for Article 5 exemption criteria, validity periods, renewal timing, continued validity during review, transition after rejection or revocation, Annex V application content, and current Annex entries.
  • Current Article 5, Annex III, Annex IV, and Annex V support tracking exemptions by material, component, specific application, category, wording, and granting, renewal, or revocation status.
  • Current Article 5 gives the validity periods, 18-month renewal filing rule, continued validity during renewal review, and 12-to-18-month transition after rejection or revocation.
Show 2 more
  • Current Annex V lists the minimum information expected for granting, renewing, or revoking RoHS exemptions.
  • Current Annex III and Annex IV entries show wording, category scope, and expiry dates that must be checked entry by entry.
European Commission - RoHS Directive implementation
environment.ec.europa.eu4 citations
Referenced sections
  • Commission source for the exemption procedure, official exemptions list, application guidance, 18-to-24-month decision timing, and assessment-study process.
  • Commission implementation page explains the exemption procedure, official exemptions list, application form, and assessment-study sources.
  • Commission source for the 18-to-24-month decision timeframe and procedural steps after exemption applications.
Show 1 more
  • Commission implementation source for exemption reassessment factors, decision timing, and the rule that a new exemption request does not itself permit market placement.
"Exemptions are limited in time"
More quoted passages
"18 to 24 months"
"must comply with the Directive"
European Commission - RoHS exemption application guidance
environment.ec.europa.eu2 citations
Referenced sections
  • Commission-linked guidance for checking whether an existing exemption applies and whether a new, renewed, amended, or deleted exemption should be pursued.
  • Commission-linked guidance explains who may need to check existing exemptions, renewals, wording changes, or deletion requests.
"criteria for exemption are applicable"
More quoted passages
"check whether an existing exemption either applies"

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