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Exemptions under RoHS for lead as an alloying element in steel, aluminium and copper

Environment

Certain hazardous substances are restricted in electrical and electronic equipment (EEE) under the RoHS Directive. Specific, time-limited exemptions can be granted upon request from economic operators if the necessary criteria are met. The exemptions under assessment concerns lead as an alloying element in steel, aluminium and copper, which are used in the manufacture of EEE.

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Public consultation

ID: 14172

Lobbying Activity

17 responses

Automotive group ACEA urges extension of lead use exemptions

Association des Constructeurs Européens d'Automobiles, 10 Feb 2025

ACEA requests alignment with previous decisions to avoid expiry dates considered unusually short and extremely challenging. They argue splitting exemptions only adds to the burden of industry.
This prevents production halts since technical solutions for lead-free alternatives are currently unavailable.
Environmental groups lose out as lead remains in the electronics supply chain longer.

DIGITALEUROPE calls for longer lead exemptions in electronic manufacturing

DIGITALEUROPE, 10 Feb 2025

The organization requests extending lead exemption expiry dates to at least two years after publication. They oppose splitting general exemptions into burdensome sub-categories and adding restrictive footnotes that remove existing regulatory protections.
Extending exemptions would help companies avoid unnecessary compliance costs and maintain market access.
Small businesses risk exclusion from the market due to complex reporting requirements.

CLEPA warns against short deadlines for lead exemptions

European Association Automotive Suppliers, 10 Feb 2025

CLEPA requests aligning expiry dates with previous decisions because current proposals are unusually short and extremely challenging. They oppose splitting exemptions that only add burden and reject replacing REACH derogations.
Extended deadlines would help suppliers avoid the burden of extremely challenging technical transitions.
Public health interests lose higher protection levels potentially offered by splitting specific exemptions.

MedTech Europe urges extended lead exemption transition periods

MedTech Europe, 7 Feb 2025

The organization requests 18-month transitional periods for categories 8 and 9 medical technologies, at least two additional years for exemption renewals compared to other product categories, and a fall-back mechanism for applications not captured in new sub-entries. They argue current 12-month timelines are insufficient given complex supply chains and requalification requirements under medical device regulations.
This would prevent market discontinuation of medical technologies and give manufacturers time to requalify products under stringent sectoral requirements.
Patients and healthcare facilities lose access to diagnostic tests and medical devices if equipment becomes prematurely obsolete.

European Aluminium urges immediate end to lead exemptions in electronics

European Aluminium AISBL, 10 Feb 2025

The association demands an immediate end to intentional lead use in aluminium alloys. They support a new exemption for recycled scrap with a reduced lead limit.
This would prevent EU producers from facing expensive safety and transport compliance costs.
Non-EU manufacturers would lose their current competitive edge over highly regulated European plants.

Appliance industry urges longer lead exemptions for electronics

APPLiA (Home Appliance Europe), 10 Feb 2025

APPLiA requests extended deadlines and opposes splitting exemptions into specific sub-entries. They argue the proposed changes create unnecessary complexity and administrative burdens.
Maintaining current exemptions prevents supply chain disruptions and avoids unnecessary administrative costs.
Consumers could face reduced product availability and safety risks from untested material alternatives.

Test & Measurement Coalition urges longer lead exemptions for industry

EPPA SA, 10 Feb 2025

The coalition urges the Commission to renew lead exemptions for the maximum seven-year validity period. They argue that the proposed 2026 expiration date provides insufficient time for complex industrial testing. They also oppose splitting exemptions, which they claim adds administrative burden without environmental benefit.
Longer validity periods would prevent billions in losses and maintain the sector's economic competitiveness.
Strategic industries and public health services lose access to indispensable research and diagnostic equipment.

Industry coalition urges longer deadlines for lead use exemptions

European Coordination Committee of the Radiological, Electromedical and healthcare IT Industry, 10 Feb 2025

The group requests extending lead exemption expiry dates to two years after publication. They claim splitting exemptions adds burden and forces changes based on bureaucracy.
This would reduce compliance costs and prevent many products from being banned.
Children and the environment lose protections if lead safety restrictions are removed.

EHI warns short lead exemption timelines threaten industry supply

Association of the European Heating Industry, 10 Feb 2025

The association calls for extending exemption expiry dates to at least two years after publication. They argue against splitting exemptions into sub-categories, which adds unnecessary administrative burdens. They also oppose new footnotes restricting lead release from consumer products.
Longer timelines would prevent compliance backlogs and ensure technical continuity for manufacturers.
Consumers could lose access to electronic products due to immediate market bans.

JBCE urges EU to include more categories in lead exemptions

Japan Business Council in Europe, 10 Feb 2025

The group suggests adjusting the scope to ensure medical devices and monitoring instruments are included. They request a longer validity period for products with long design cycles and certification requirements.
This extension provides more time to redesign specialized products with long life cycles.
Environmental safety suffers as toxic lead remains in the market for longer.

SPECTARIS Urges Longer Transitions for Lead Use Exemptions

SPECTARIS Deutscher Industrieverband für Optik, Photonik, Analysen- und Medizintechnik e.V., 10 Feb 2025

SPECTARIS requests extending transition periods for non-renewable exemptions to 18-36 months. They advocate for maximizing the duration of renewable exemptions and including medical devices. The group recommends avoiding unnecessary subdivisions of exemptions to reduce complexity.
This would allow companies sufficient time for complex testing and mandatory re-certification.
Medical and research sectors risk supply shortages of essential high-tech equipment.

Consultation response

Emerson Electric Co., 6 Feb 2025

Subject: Concerns Regarding the EU Commissions Draft Delegated Directive for Lead as an Alloying Element in Copper 6(c) Emerson Electric commends the EU Commission for allowing industrys participation in the Draft Delegated Directive for lead in high melting solders and recognizes the significance…

Consultation response

AQUA - Association Européenne des Fabricants de Compteurs d’Eau et d’Energie Thermique, 7 Feb 2025

AQUA www.aqua-metering.org is the Association of European Manufacturers in the Smart Water and Thermal Energy meters field. AQUA members like Kamstrup, Honeywell, Diehl, Landis + Gyr are operating in all EU countries and Switzerland and constantly investing in new technologies to meet industry…

Consultation response

ARGE – The European Federation of Locks & Building Hardware Manufacturers, 10 Feb 2025

ARGE The European Federation of Locks and Building Hardware Manufacturers welcomes the opportunity to comment on the draft Delegated Directives published for Public Consultation on the Have Your Say portal on 13 January 2025. ARGE's feedback on Hazardous substances exemption for lead as an alloying…

Consultation response

International Wrought Copper Council, 10 Feb 2025

The International Wrought Copper Council (IWCC) is the global association for the copper and copper alloy semis fabricating industry. In Europe, the IWCC has established a Brass Rod Committee of its members in accordance with IWCC Guidelines comprising a number of European brass rod manufacturers.…

Consultation response

The Association of Manufacturers and suppliers of Power Systems and ancillary equipment, 10 Feb 2025

As The Association of Manufacturers of Power generating Systems (AMPS) We welcome the opportunity to provide feedback on the European Commissions draft amendment to directive 2011/65/EU (Regarding exemption for lead as an alloying element in steel, aluminium and copper) Ref. Ares(2025)216290 Our…

Consultation response

European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers, 5 Feb 2025

EUROMOT, the European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers supports the feedback submitted by the Umbrella Project to this consultation.