RoHS exemptions tracker guide

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.

Operational example: a supplier cites an exemption number, but the entry covers a different product category. Record the category mismatch and mark that claim as not applicable. Ask the material reviewer for evidence of compliance without that exemption or another applicable entry before approving the claim.

For an existing exemption, show that the actual substance, material or component, application, EEE category, and placement date fit the exact Annex entry. Annex V sets the dossier requirements for a person applying to grant, renew, or revoke an exemption; it does not require every manufacturer relying on an existing entry to submit an application or recreate that dossier.

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.

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 timely renewal application 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.

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.