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Exemptions under RoHS for lead in high melting temperature type solders

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 exemption under assessment concerns lead in high melting temperature type solders, used in EEE.

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Public consultation

ID: 14170

Lobbying Activity

10 responses

ACEA urges extension for lead solder exemptions in electronics

Association des Constructeurs Européens d'Automobiles, 10 Feb 2025

ACEA requests extending the proposed expiry dates and objects to the detailed splitting of exemptions. They argue current timelines are unrealistic and increase administrative burden without improving environmental protection.
The industry avoids technical disruption and high compliance costs while suitable lead-free alternatives remain unavailable.
Environmental advocates lose the benefit of a more rapid phase-out of hazardous lead substances.

DIGITALEUROPE warns short lead exemption deadlines burden industry

DIGITALEUROPE, 10 Feb 2025

The group requests extending the proposed expiry dates to at least two years. They oppose splitting current exemptions into complex sub-categories for technical components. They also reject new footnotes that would restrict lead alloys in consumer products.
Aligning dates and maintaining general exemptions would reduce compliance costs and administrative burdens.
Small businesses and electronic manufacturers face exclusion from the market due to impossible timelines.

CLEPA Demands More Time for Lead Solder Rule Changes

European Association Automotive Suppliers, 10 Feb 2025

The organization requests delaying expiry dates to match previous regulatory decisions. They also oppose splitting exemptions, claiming it adds unnecessary industry burden.
Longer deadlines would help suppliers avoid immediate and costly manufacturing changes.
Health and environment groups lose from delayed reductions in hazardous lead exposure.

MedTech Europe urges extended timelines for lead exemption phase-out

MedTech Europe, 7 Feb 2025

The organization requests 18-month transitional periods for medical device categories and at least 2 additional years for exemption renewals compared to other sectors. They argue current 12-month timelines are insufficient given the complex multi-tier supply chain and stringent medical device requalification requirements.
This would prevent premature discontinuation of medical devices and allow time to requalify products under EU medical technology legislation.
Patients lose access to diagnostic tests and medical devices if manufacturers cannot source compliant components in time.

SNCF Urges Lead Exemption Extension for Railway Maintenance

Société nationale SNCF, 10 Feb 2025

SNCF warns that restricting lead exemptions would severely disrupt maintenance and the availability of railway equipment. They argue that lead-free processes use temperatures too high for legacy electronic components to withstand.
This would help SNCF avoid high financial costs and equipment obsolescence caused by forced redesigns.
Railway passengers could face service disruptions and risks to essential safety functions.

Test & Measurement Coalition Urges Renewal of Lead Exemptions

EPPA SA, 10 Feb 2025

The coalition urges the Commission to renew exemptions in existing wording for the maximum validity periods. They oppose splitting the current exemption into seven sub-categories to avoid unnecessary administrative burdens. They also request the full seven-year extension required for complex technical verification.
This renewal would prevent massive economic losses and reduce complex supplier management costs.
Strategic EU industries and national enforcement authorities would lose access to essential diagnostic tools.

Medical technology groups urge longer RoHS lead exemption periods

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

The industry group requests extending proposed expiry dates to at least two to five years after official publication. They oppose splitting exemptions into sub-categories, arguing this creates unnecessary bureaucratic burdens without technical justification. They also reject adding footnotes that duplicate other chemical regulations, which could immediately ban specific electronic products.
Extending these exemptions reduces administrative costs and prevents the immediate withdrawal of vital equipment.
Consumers may lose access to products like electronic keys due to uncoordinated regulatory changes.

SPECTARIS urges longer transition periods for lead solder exemptions

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

SPECTARIS requests extending transition periods to at least 18-36 months. They seek additional time for medical devices to accommodate complex safety re-certification processes.
Companies would avoid high redesign costs and disruptions to international supply chains.
Patients and researchers face supply risks for critical medical and analytical equipment.

Consultation response

Emerson Electric Co., 6 Feb 2025

Subject: Concerns Regarding the EU Commissions Draft Delegated Directive for Lead in High Melting Temperature Solders 7(a) Emerson Electric commends the EU Commission for allowing industrys participation in the Draft Delegated Directive for lead in high melting solders and recognizes the…

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.