EU RoHSTracker guide

RoHS exemptions tracker guide

RoHS exemptions are temporary, application-specific permissions in Annex III or Annex IV, not blanket approvals for a company, product line, or supplier.

This guide helps design tracker fields, evidence links, renewal alerts, and release gates that keep each exemption claim tied to the exact material, component, use, category, and source.

Back to main artifactReview sources
Author
Sorena AI
Published
May 9, 2026
Updated
Jul 25, 2026
Sections
4

Structured answer sets in this page tree.

Primary sources
7

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 25, 2026
Overview

A should make one release-critical answer visible: whether a specific restricted substance in a specific material or component is covered by the exact Annex III or Annex IV wording, for the right EEE category and date, with enough evidence to support the technical documentation and EU declaration of conformity.

Section 1

Core fields for a RoHS exemptions tracker

Do not track exemptions as a generic "RoHS exempt" label. The Commission FAQ explains that exemptions are granted for specific substances used in specific applications, not for a whole EEE product or a company.

Each tracker row should therefore connect the legal entry to the product facts that make the claim true. The row is useful only when a reviewer can see the Annex, exemption wording, EEE category, material or component, substance, expiry or renewal timing, evidence owner, and release decision without reconstructing the history from email.

  • Keep one row per exemption claim, with fields for Annex III or Annex IV, exemption number, exact wording, restricted substance, homogeneous material, component, application, EEE category, product or SKU coverage, supplier, and source URL.
  • Capture the date basis separately: stated expiry date, renewal application deadline, renewal-under-review flag, rejection or revocation transition date where applicable, and the date the row was last verified against the Commission or Eur-Lex source. Do not copy one category's expiry date to another category covered by the same numbered entry.
  • Use explicit status values: active, renewal pending, new request pending, rejected or revoked in transition, expired, or not applicable. A pending renewal and a pending request for a new exemption have different legal effects.
  • Link evidence directly: supplier declaration, material declaration, BOM line, test or engineering rationale, substitution analysis, technical-documentation section, EU DoC rationale, owner, internal reviewer, and next review trigger.
  • Keep proposed or pending new exemption requests separate from release-approved claims. Until an exemption is granted and reflected in the legal source, the tracker should not treat it as permission to place non-compliant EEE on the EU market.
Sources for this answer
Directive 2011/65/EU on restriction of hazardous substances (RoHS)
Binding consolidated RoHS source for Article 5, Annex III, Annex IV, Annex V application contents, technical documentation, CE marking, and economic-operator duties.
European Commission RoHS FAQ
Commission FAQ source for Annex III and IV distinctions, application-specific exemptions, maximum validity periods, homogeneous material principles, and technical-documentation context.
European Commission - RoHS Directive implementation
Commission implementation source for exemption procedure, renewal timing, pending-renewal validity, and assessment-study process.
Section 2

Evidence needed before relying on an exemption

A tracker row should prove more than the existence of an Annex entry. Directive 2011/65/EU Annex V requires exemption applications to identify the material or component, the specific uses of the substance, verifiable and referenced justification, alternatives analysis, and reuse or recycling information where relevant.

For product compliance, the evidence package should also fit the manufacturer's technical-documentation obligation. Commission Implementing Decision (EU) 2020/659 identifies EN IEC 63000:2018 as the harmonised standard for technical documentation used to assess materials, components, and EEE against RoHS substance restrictions.

  • For the material claim: store the BOM line, homogeneous-material definition used, restricted substance, concentration basis where available, supplier declaration, and any test or risk-screening result.
  • For the exemption fit: store the exact Annex wording, why the component use matches it, any category or application limitation, and why the claim does not spill over to adjacent materials or assemblies.
  • For the Article 5 rationale: keep evidence on substitution practicability, substitute reliability, environmental, health and consumer-safety impacts, availability, socioeconomic considerations, and innovation impacts when those points support the claim.
  • For release review: link the tracker row to EN IEC 63000 technical documentation, internal production control evidence, EU DoC review, and change-control history.
Sources for this answer
Directive 2011/65/EU on restriction of hazardous substances (RoHS)
Binding source for Annex V minimum application contents and manufacturer technical-documentation duties.
Guidance document for RoHS exemption applications
Commission-linked guidance for Article 5 exemption requests, renewals, wording changes, deletion requests, criteria, documentation, and timelines.
Commission Implementing Decision (EU) 2020/659 on EN IEC 63000
Official source identifying EN IEC 63000:2018 as the harmonised technical-documentation standard for RoHS restricted-substance assessment.
IEC 63000:2016 technical documentation standard
IEC source describing IEC 63000 as technical documentation compiled to declare compliance with applicable substance restrictions.
Recommended next step

Turn exemption rows into release gates

Build a RoHS tracker that ties each Annex III or IV claim to product facts, supplier evidence, renewal timing, EN IEC 63000 documentation, and a clear release decision.

Research workflow
Open Research Copilot

Ask RoHS exemption, renewal, and evidence questions with cited outputs.

Explore next step
Talk to Sorena
Talk through implementation

Review tracker fields, release gates, owners, and evidence gaps.

Explore next step
Section 3

Renewal timing and release gates

Use exemption timing as a release gate. The Commission implementation page states that a renewal application must be made no later than 18 months before the exemption expires, that RoHS exemption decisions currently take 18 to 24 months from the application date, and that existing exemptions with a submitted renewal request remain valid until the Commission decides.

Review every expiring row before release. Confirm whether the submission is a renewal of the same exemption or a request for a new exemption. The Commission states that EEE must comply until a new exemption is granted; a pending new request is not permission. For a renewal, the tracker should show that the exact product claim still matches the existing wording and whether a delegated act, rejection, revocation, or transition period has changed the decision.

  • Gate new product release if the exemption has expired, does not match the product category or application, or depends only on a pending new exemption request.
  • Escalate rows inside the 18-month renewal window if no renewal evidence or substitution plan is recorded.
  • After a rejection or revocation decision, record the legally supported transition period instead of inventing an internal grace period.
  • Reopen rows after supplier changes, material changes, component redesign, new test evidence, Annex wording changes, category changes, or technical-documentation updates.
Sources for this answer
European Commission - RoHS Directive implementation
Commission source for the no-later-than-18-month renewal filing rule, 18 to 24 month decision timing, and continued validity while renewal decisions are pending.
Directive 2011/65/EU on restriction of hazardous substances (RoHS)
Binding source for Article 5 renewal, rejection, revocation, and expiry timing rules.
Guidance document for RoHS exemption applications
Guidance source for exemption renewal timing, wording changes, deletion requests, and planning around substitution or production changes.
Section 4

Common tracker failures to avoid

Avoid overbroad reliance. An Annex entry may apply only to a narrow use, category, voltage, material, or date, while the commercial product contains many homogeneous materials and assemblies that still need ordinary RoHS evidence.

Avoid stale sourcing. Because the Commission says exemptions are limited in time and reassessed regularly, each tracker row needs a source-verification date and a release decision that can change when the Annex wording, renewal status, or product facts change.

  • Do not use one supplier statement to approve every product using that supplier; tie the statement to the material, component, substance, and exemption wording.
  • Do not paraphrase Annex wording so broadly that category, application, or expiry limits disappear.
  • Do not let confidential-only material be the sole support for an exemption rationale where the public file must support the request or decision.
  • Do not mix RoHS exemption evidence with REACH, POPs, batteries, WEEE, LVD, or EMC evidence unless the tracker clearly names which legal duty each record supports.
Sources for this answer
European Commission RoHS FAQ
Commission FAQ source for application-specific exemptions, Annex III and IV structure, homogeneous-material assessment, and technical-documentation responsibility.
European Commission - RoHS exemptions list
Commission source for the downloadable exemptions list referenced from the RoHS implementation page.
Guidance document for RoHS exemption applications
Guidance source warning that confidential material should be separated and that confidential-only material cannot serve as official information supporting an exemption request.
Primary sources

References and citations

European Commission - RoHS Directive implementation
environment.ec.europa.eu
Referenced sections
  • Commission source for the no-later-than-18-month renewal filing rule, 18 to 24 month decision timing, and continued validity while renewal decisions are pending.
"remain valid until a decision is taken"
European Commission RoHS FAQ
environment.ec.europa.eu
Referenced sections
  • Commission FAQ source for application-specific exemptions, Annex III and IV structure, homogeneous-material assessment, and technical-documentation responsibility.
"not for the whole EEE"
Guidance document for RoHS exemption applications
environment.ec.europa.eu
Referenced sections
  • Guidance source warning that confidential material should be separated and that confidential-only material cannot serve as official information supporting an exemption request.
"confidential material cannot serve as official information"
IEC 63000:2016 technical documentation standard
webstore.iec.ch
Referenced sections
  • IEC source describing IEC 63000 as technical documentation compiled to declare compliance with applicable substance restrictions.
"technical documentation that the manufacturer compiles"
Related guides

Explore more topics

Are cables in scope of EU RoHS? Cable evidence, CE marking, and DoC FAQ
EU RoHS cable FAQ covering when cables are EEE, how internal and external cables are treated, when separate CE marking and a DoC are needed, and what evidence to keep.
Do Components Need EU RoHS Compliance? | RoHS FAQ
RoHS FAQ for components in electrical and electronic equipment: substance restrictions, homogeneous materials, CE marking, technical files, exemptions, and supplier evidence.
EN IEC 63000 RoHS Technical Documentation
Build EN IEC 63000:2018 technical documentation for EU RoHS with manufacturer duties, evidence selection, harmonised-standard context, and file maintenance.
EU RoHS Annex III and IV exemptions guide
How to use, renew, or challenge EU RoHS Annex III and Annex IV exemptions, with Article 5 criteria, timing rules, and evidence requirements.
EU RoHS Applicability Test for EEE Scope
Decide whether EU RoHS applies to electrical and electronic equipment, cables, spare parts, exclusions, exemptions, CE marking, and evidence records.
EU RoHS CE Marking and Declaration of Conformity
Understand RoHS CE marking, the EU Declaration of Conformity, EN IEC 63000 technical documentation, and importer or distributor checks.
EU RoHS compliance checklist for EEE
Checklist for EU RoHS scope, restricted substances, homogeneous materials, exemptions, CE marking, technical documentation, and supplier evidence.
EU RoHS Compliance Guide for EEE
Practical EU RoHS compliance guide for electrical and electronic equipment: scope, restricted substances, exemptions, CE marking, technical documentation, and supplier evidence.
EU RoHS Deadlines and Compliance Calendar
Build a RoHS calendar for scope phase-ins, phthalate dates, exemption renewals, spare-part cutoffs, EN IEC 63000 evidence, CE files, and review triggers.
EU RoHS Declarations vs Lab Tests FAQ
When supplier declarations can support EU RoHS technical documentation, when IEC 62321 lab testing is stronger evidence, and how to document the decision.
EU RoHS Directive FAQ: scope, substances, CE marking
Practical EU RoHS Directive FAQ covering EEE scope, Annex II substance limits, cables, spare parts, technical documentation, CE marking, and exemptions.
EU RoHS EEE Categories and Open Scope
Map products to EU RoHS EEE categories, category 11 open scope, Article 2 exclusions, cables, spare parts, and evidence needed for RoHS scope decisions.
EU RoHS for medical devices and monitoring equipment
RoHS category 8 and 9 guide covering application dates, Annex IV exemptions, phthalates, spare parts, CE marking, declarations, and technical documentation.
EU RoHS penalties and fines: Member State sanctions
Understand EU RoHS penalty exposure, national sanctions, the absence of one EU-wide fine table, corrective actions, recalls, and evidence records.
EU RoHS Phthalates: DEHP, BBP, DBP, DIBP
Apply RoHS rules for DEHP, BBP, DBP, and DIBP, including 0.1% homogeneous-material limits, 2019 and 2021 dates, exemptions, evidence, and testing.
EU RoHS requirements for EEE, substances, and CE evidence
Practical EU RoHS requirements guide covering EEE scope, Annex II substance limits, exemptions, technical documentation, EU declaration of conformity, CE marking, and operator evidence.
EU RoHS Restricted Substances and Thresholds | Annex II Limits
EU RoHS Annex II restricted substances and maximum concentration values by weight in homogeneous materials, including cadmium's 0.01% limit and the 0.1% limits for lead, mercury, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP.
EU RoHS Spare Parts: Repair and Reuse
Apply RoHS Article 4 to repair parts and reused recovered parts, including closed-loop conditions, phthalate carve-outs, CE evidence, and cutoff dates.
EU RoHS test plan selection workflow
Choose RoHS supplier evidence, EN IEC 63000 technical documentation, and IEC 62321 testing without over-testing or under-documenting restricted substances.
EU RoHS Timeline: Scope, Phthalates, Exemptions and Evidence
Understand which EU RoHS dates changed product scope or substance duties, which dates are historical, and which exemption, spare-part, and evidence deadlines still require action.
How should RoHS lead, mercury, and cadmium exemptions be documented? | RoHS FAQ
RoHS FAQ on documenting lead, mercury, and cadmium exemptions with Annex III or IV entries, material-level limits, expiry status, supplier evidence, and technical documentation.
RoHS BOM evidence intake workflow
Build a RoHS BOM evidence intake process for EEE: map parts to homogeneous materials, collect supplier declarations, handle exemptions, and feed EN IEC 63000 technical documentation.
RoHS exemption register workflow: expiry, renewal, evidence
Build a RoHS exemption register that tracks Annex III and IV entries, product scope, expiry dates, renewal status, evidence owners, and Commission source links.
RoHS Exemptions Tracking Register
Track EU RoHS Annex III and IV exemptions by material, component, category, expiry date, renewal status, Article 5 rationale, and evidence record.
RoHS Homogeneous Material Definition and Limits
Plain-English EU RoHS FAQ on homogeneous materials, Annex II thresholds, coatings, cables, assemblies, and evidence needed for material-level RoHS decisions.
RoHS Homogeneous Material Thresholds
EU RoHS guide to homogeneous material thresholds: 0.1% limits, the 0.01% cadmium limit, material splitting, coatings, samples, exemptions, and technical evidence.
RoHS importer checks for imported EEE before EU market placement
Importer-focused RoHS FAQ covering CE marking, EU declaration of conformity, technical documentation availability, importer identity, nonconformity handling, and 10-year DoC retention.
RoHS Risk-Based Testing Guide
Choose proportionate EU RoHS verification using supplier evidence, EN IEC 63000 documentation, IEC 62321 methods, and product-specific risk decisions.
RoHS Supplier Change Control Workflow
Control EU RoHS risk after part substitutions or material changes by reassessing supplier declarations, test needs, exemptions, and technical-file updates.
RoHS Supplier Declaration Template
Use a structured EU RoHS supplier declaration to collect material evidence, exemption claims, test records, and EN IEC 63000 technical-file inputs.
RoHS Supplier Declarations and Verification Guide
Build a RoHS supplier evidence file without confusing supplier declarations with manufacturer EU DoC, CE marking, technical documentation, or importer checks.
RoHS Supplier Declarations Guide
Use RoHS supplier declarations as supporting evidence for BOM, material, exemption, and technical-file reviews without replacing manufacturer EU DoC or CE duties.
RoHS technical documentation, EU DoC and CE marking
Connect RoHS technical documentation and EN IEC 63000 evidence to the EU declaration of conformity, CE marking, and economic-operator duties.
RoHS vs Batteries Regulation scope comparison
RoHS-focused comparison explaining when RoHS applies to EEE, why batteries sit outside RoHS, and what evidence should not be reused without separate battery-law support.
RoHS vs LVD/EMC CE evidence: what belongs in the RoHS file
Compare RoHS substance evidence with separate LVD and EMC CE evidence streams across scope, technical files, declarations, CE marking, exemptions, and supplier records.
RoHS vs POPs for EEE substance compliance
Compare EU RoHS and POPs obligations for electrical and electronic equipment: scope, substances, evidence, CE files, exemptions, waste overlap, and cited decision rules.
RoHS vs REACH for electronics: scope, evidence, overlap
Compare EU RoHS and REACH for electrical and electronic equipment: scope, restricted substances, evidence, CE marking, exemptions, and overlap decisions.
RoHS vs WEEE: EU electronics compliance comparison
Compare EU RoHS restricted-substance duties with WEEE end-of-life recycling obligations, with RoHS scope, evidence, CE marking, exemptions, and cited decision points.
RoHS, REACH, POPs, and batteries overlap
Separate RoHS restrictions and evidence from REACH, POPs, Batteries Regulation, waste, and adjacent technical-file workstreams for the same product.
What do the 0.1% and 0.01% substance limits mean under EU RoHS? | RoHS FAQ
RoHS FAQ explaining why most Annex II substances use a 0.1% homogeneous-material limit while cadmium uses 0.01%.
What should teams do before a RoHS exemption expires? | RoHS FAQ
How to handle EU RoHS exemption expiry: confirm the Annex entry, renewal deadline, pending-decision status, fallback plan, and technical-file evidence.
When can RoHS spare parts use transition rules? | RoHS FAQ
EU RoHS FAQ on spare parts, repair parts, reused parts, closed-loop B2B reuse, legacy EEE cutoffs, Annex III and IV exemptions, and evidence to keep.
Which EEE is in scope under EU RoHS? | RoHS FAQ
EU RoHS scope FAQ explaining when a product is electrical and electronic equipment, which Article 2 exclusions to check, and what evidence to keep.