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Exemptions under RoHS for lead in glass or ceramic of electrical and electronic components

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 in glass or ceramic of electrical or electronic components, including dielectric ceramic in capacitors.

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Public consultation

ID: 14171

Lobbying Activity

18 responses

European Car Makers Demand Extension for RoHS Lead Exemptions

Association des Constructeurs Européens d'Automobiles, 10 Feb 2025

ACEA requests aligning expiry dates with past decisions to avoid extremely challenging deadlines. They oppose splitting exemptions into complex sub-entries that increase industry burden.
Longer timelines reduce compliance costs and prevent disruption where technical solutions are missing.
Environmental and health advocates lose if hazardous substance phase-outs are delayed.

DIGITALEUROPE warns against short RoHS lead exemption deadlines

DIGITALEUROPE, 10 Feb 2025

DIGITALEUROPE requests extending exemption deadlines to at least two years after publication. They oppose splitting broad exemptions into sub-categories to avoid supply chain data issues. They also reject adding restrictive chemical regulation footnotes to the current rules.
Maintaining existing exemptions reduces administrative costs and prevents product exclusion from the market.
Small businesses and market authorities face burdens from complex new reporting and testing requirements.

CLEPA seeks longer lead exemptions for electronic car components

European Association Automotive Suppliers, 10 Feb 2025

CLEPA requests extending expiry dates and aligning them with previous decisions. They oppose splitting exemptions to avoid unnecessary administrative work.
This would prevent increased administrative burdens and technical challenges for suppliers.
Environmental advocates lose the potential health protections of stricter, more granular chemical restrictions.

MedTech Europe urges longer 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 2 years additional renewal time compared to other product categories, and fall-back mechanisms for applications not captured in new sub-entries. They argue current 12-month timelines are insufficient given complex supply chains and medical device requalification requirements.
This would give manufacturers more time to source alternatives and requalify products under medical device regulations.
Patients lose access to diagnostic and treatment technologies if devices become obsolete without viable alternatives.

APPLiA warns against short deadlines for lead use exemptions

APPLiA (Home Appliance Europe), 10 Feb 2025

APPLiA requests longer deadlines for lead exemptions and rejects splitting them into complex sub-categories. They argue that safe, technically viable alternatives are currently unavailable for many appliances.
This would prevent costly production halts and reduce the administrative burden of regulations.
Consumers risk using unsafe appliances and losing access to essential household electronics.

Infineon warns new lead restrictions threaten EU green transition

Infineon Technologies AG, 10 Feb 2025

The company requests maintaining broader exemptions because lead-free alternatives currently lack reliability for specialized components. They suggest extending the transition period to manage their extensive portfolio of over one thousand products.
Maintaining the current exemptions avoids massive technical and administrative burdens across their entire portfolio.
The EU green transition may suffer if components for renewable energy and e-mobility lack exemptions.

Test & Measurement Coalition urges 7-year lead exemption renewal

EPPA SA, 10 Feb 2025

The coalition requests the renewal of lead exemptions for the maximum seven-year period. They oppose splitting the existing exemption, arguing it creates unnecessary administrative work. Technical alternatives are not currently available for their complex industrial products.
Renewal prevents multibillion-euro economic losses and avoids technical disruption to complex supply chains.
Healthcare and telecommunications sectors lose access to essential diagnostic and research tools.

Industry groups urge longer RoHS lead exemption periods

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

Industry requests aligning expiry dates with past decisions, allowing at least two to five years after publication. They oppose complex rewordings and new footnotes that increase bureaucratic burden without technical justification.
This would reduce bureaucratic burdens and prevent sudden product bans across the single market.
Environmental health protections are weakened by delaying the phase-out of lead in electronic components.

Heating industry urges longer RoHS lead exemption timelines

Association of the European Heating Industry, 10 Feb 2025

The association requests extending expiry dates to at least two years after official publication for existing exemptions and five years for split categories. They also oppose new sub-exemptions and restrictive footnotes that could immediately ban essential electronic products.
Extended timelines and fewer sub-exemptions reduce administrative burdens and maintain market access.
Environmental groups lose because toxic lead remains in products longer without stricter controls.

High-tech association SPECTARIS urges longer lead exemption transitions

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

The association recommends extending transition periods to 18-36 months for non-renewable exemptions. They demand maximizing exemption durations to accommodate long medical development and validation cycles. The group also advocates for including medical devices and monitoring instruments in exemptions.
This prevents financial losses and helps companies maintain stable international supply chains.
Patients and researchers face supply risks if critical medical or laboratory equipment becomes unavailable.

Consultation response

Emerson Electric Co., 6 Feb 2025

Subject: Concerns Regarding the EU Commissions Draft Delegated Directive for Lead in Glass or Ceramic Components for Exemption 7(C) Emerson Electric commends the EU Commission for allowing industrys participation in the Draft Delegated Directive for lead in glass or ceramic components and…

Consultation response

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

AQUA 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 needs for more frequent…

Consultation response

TE Connectivity Belgium BV, 7 Feb 2025

Our company makes a very diverse portfolio of products used in multiple market sectors that require the use of lead in glass and ceramics for functionality and reliability. We propose to submit a detailed list of hundreds of specific product codes so specific terms are incorporated in the proposed…

Consultation response

Mitsubishi Electric Europe, 7 Feb 2025

Mitsubishi Electric supports the overall objectives of the RoHS Directive and remains committed to continue supporting the procedure for adaptation to scientific and technical progress. We also support targeted adaptations where warranted from a standpoint of practicability, reliability and…

Consultation response

Verband der Keramischen Industrie e.V., 10 Feb 2025

Dear Sir or Madam, The Federal Association of the Ceramic Industry (BVKI) welcomes the opportunity to comment on the proposed amendment to Annex III of Directive 2011/65/EU (RoHS), particularly concerning the exemption for lead in glass and ceramic components of electrical and electronic equipment.…

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 in glass or ceramic components) Ref. Ares(2025)216368 Our members would be directly…

Consultation response

Barco, 6 Feb 2025

The proposed expiry dates (31 December 2026 or 2027) are very short. While we appreciate the difficulty of managing the RoHS file, the long delay of the European Commission in assessing the requests, submitted in 2020, should not result in deadlines so short to put an extreme burden on companies.…

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.