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Stakeholder consultation on exemptions from the substance restrictions in electrical and electronic equipment (RoHS Directive)

The consultation is closed.

This stakeholder consultation ran for eight weeks from 24.01.2012 to 20.03.2012 and covered the following 18 exemption requests:

Exemption request 1 "Cadmium and its compounds in electrical contacts or one shot pellet type thermal cut-offs with current ratings of 5 Amperes or more, for use in monitoring and control instruments (Category 9.)"

Exemption request 3 "Cadmium in phosphor coatings in image intensifiers for X-ray images"

Exemption request 4 "Lead acetate marker for use in stereotactic headframes for use with CT and MRI and in positioning systems for gamma beam and particle therapy equipment"

Exemption request 5 "Lead as an alloying element as a lubricant for bearings and wear surfaces in radiotherapy equipment and radiosurgery equipment and for patient and equipment support systems"

Exemption request 6 "Lead to enable thermal compression process to make a vacuum tight connection between aluminium and steel for X-ray image intensifiers"

Exemption request 7 "Lead in non-magnetic pin connector systems used at temperatures below minus 20°C"

Exemption request 8 "Lead in solder for electrical circuitry that is used at temperatures below -20°C"

Exemption request 9 "Lead in solders and solderable coatings used on non-magnetic components and circuits that are used in magnetic fields or are associated with circuits used inside strong magnetic fields"

Exemption request 10 "Lead in solders to PCBs for mounting cadmium telluride and cadmium zinc telluride digital array detectors"

Exemption request 12 "Lead and cadmium in optical and filter glass in monitoring and control instruments (Category 9.)"

Exemption request 13 "Lead and cadmium in metallic bonds creating superconducting magnetic circuits"

Exemption request 14 "Lead in alloys as a superconductor and thermal conductor in devices that depend on superconductivity for their operation"

Exemption request 15 "Lead not exceeding 20% in bronze bearings and bushes in monitoring and control instruments (Category 9.)"

Exemption request 16 "Lead in solders consisting of more than two elements for the connection between the pins and the package of microprocessors with a lead content of more than 80% and less than 85% by weight used in monitoring and control instruments (Category 9)"

Exemption request 17 "Lead in glass of electronic components and fluorescent tubes, or in electronic ceramic parts (including dielectric ceramic capacitors) used in monitoring and control instruments (Category 9.)"

Exemption request 18 "Lead used in compliant pin connector systems for use in monitoring and control instruments (Category 9)"

Exemption request 19 "Handicraft luminous discharge tubes (HLDT) used for signs, decorative lighting and light-artwork, in fixed or portable installations as per definition in EN50107-1(2002) “1 Scope” and in prHD60364-7-719 number 719-1"

Exemption request 20 "Mercury in cold cathode fluorescent lamps and external electrode fluorescent lamps (CCFL and EEFL) for special purposes not exceeding 5 mg per lamp in lighting applications for monitoring and control instruments (Category 9)"


Please note that request No. 2 and 11 have been submitted to the Commission but are not part of the current project and are therefore not listed here.

Guidance document

The guidance document contains information on

  • the objective of the consultation,
  • how to submit your contribution,
  • contact details.

> Download guidance document on the stakeholder consultation (PDF)

The sections Request 1, Request 3, Request 4, Request 5, Request 6, Request 7, Request 8, Request 9, Request 10Request 12, Request 13, Request 14, Request 15, Request 16, Request 17, Request 18, Request 19 and Request 20 contain further necessary information (e.g. questionnaire and results of former evaluations).

Results of the consultation and next steps

Non-confidential information submitted during the consultation will be posted on the EU CIRCA website (Browse categories > European Commission > Environment > RoHS 2012 Exemptions Review, at top left, click on "Library"). The contributions will also be made available at this webiste in the corresponding request sections.

Further exchange with stakeholders will be held after the consultation has ended for those issues where further need for information and / or need for (technical) discussion has been identified.

Target groups

The consultation is targeted at the following groups:

  • EEE industry
  • EEE industry federations
  • Consultancies
  • Research institutions & universities
  • NGOs (environmental, consumer, employee or other)
  • Public administrations
  • Recycler / Waste Treatment Operator

> List of interested stakeholders

Please take note of the specific privacy statement and of personal data protection.

Should there be any mistakes or uncertainties we apologise for the inconvenience and kindly ask you to provide us with a short indication.