EU RoHS Compliance in 2024: What to Expect

The European Union (EU) was expected to adopt a proposed revision last year that would add two additional chemicals, TBBP-A and MCCPs, to the Restriction on Hazardous Substance (RoHS) restricted substances list. However, the revision – which is expected to significantly impact EU Member States – has once again been postponed with no recent updates. Despite this delay, there are many other changes to EU RoHS for which manufacturers must be prepared. Continue reading to learn more about what to expect from EU RoHS compliance in 2024.  

What are the latest revisions to the EU RoHS Directive?

For 2024, the EU RoHS directive has been amended with Directive (EU) 2024/232. Also, the proposed substance additions to increase the list of restricted substances from 10 to 12 could be adopted during the year. There are also several exemption expirations and renewals to be aware of. Our team of experts compiled the most important updates to help you prepare for what’s coming this year. 

Directive (EU) 2024/232

On January 10th, 2024, the European Commission published Directive (EU) 2024/232, amending Directive 2011/65/EU. The new directive includes an exemption for cadmium and lead in plastic profiles in electrical and electronic windows and doors containing recovered rigid polyvinyl chloride (PVC). Directive 2024/232 went into effect on January 30, 2024, and the exemption expires on May 28th, 2028. 

The scope of the exemption is limited to the current cadmium and lead restriction entries and has been aligned with the derogation for lead in recovered PVC outlined in Regulation (EU) 2023/923. The electrical and electronic equipment and applications covered in the exemption fall under category 11 of Annex I and Annex III of Directive 2011/65/EU, respectively. 

Annex III of Directive 2011/65/EU is amended by the addition of entry 46 as set out in the Annex to Directive (EU) 2024/232, which includes the following: 

  • Cadmium and lead in plastic profiles containing mixtures produced from polyvinyl chloride waste, used for electrical and electronic windows and doors, where the concentration in the recovered rigid PVC material does not exceed 0.1 % cadmium by weight and 1.5 % lead by weight. 
  • Beginning on May 28th, 2026, rigid PVC recovered from electrical and electronic windows and doors must only be used to produce new articles under the categories specified in entry 63, points 18(a) to (d) of Annex XVII to Regulation (EC) No 1907/2006. 
  • Suppliers of PVC articles containing recovered rigid PVC with a concentration of lead equal to or greater than 0.1 % by weight of the PVC material must ensure that the articles are clearly marked with the statement “Contains ≥ 0.1 % lead” before placing those articles on the market. If the marking is unable to be included on the article, it must be included on the packaging. 

EU Member States must adopt and publish the necessary provisions by July 31st, 2024. The provisions will be applied beginning August 1st, 2024. 

Proposed Substance Additions

In 2023, the European Commission proposed adding two new substances to the restricted substance list: tetrabromobisphenol A (TBBPA) and medium-chain chlorinated paraffins (MCCPs). Adding TBBPA and MCCPs would increase the number of restricted substances under EU RoHS from 10 to 12. The proposal's adoption was expected by the end of 2023, but it is currently on hold as of early 2024. 

  • TBBPA is a flame retardant commonly used to reduce the flammability of plastics and synthetic resins in consumer products, including electrical and electronic equipment parts. It is being considered as an addition to the restricted substances list due to its potential to harm human health, as it is a known carcinogen.
  • MCCPs are industrial chemicals often used as flame retardants or plasticizers in plastics, rubber, adhesives, paints, and more. They are also used in metal operations as lubricants or coolants. MCCPs are being considered as an addition to the restricted substances list because they are expected to be bio-accumulative and are considered toxic to the environment by some agencies.  

Exemption Expirations

Multiple exemptions contained in Annex III and Annex IV are set to expire in 2024 and are no longer renewable. Most of the exemptions apply to categories 9 (industrial monitoring and control instruments) and 11 (other electrical and electronic equipment). 

Exemption Renewals

Several exemptions within Annex III and Annex IV are currently under review for renewal. Commonly used exemptions are included in the requested renewals, such as: 

  • 4 (Annex IV) 
  • 9 (Annex IV) 
  • 10 (Annex IV) 
  • 18(b) (Annex III) 

Looking to learn more about EU RoHS? Enroll in our on-demand course, Introduction to EU RoHS, offered through Source Academy. Sign in and enroll in the course if you already have an account, or if you’re new to Source Academy, sign up and request an access code to get started. 

Prepare for Changes to EU RoHS in 2024 with Source Intelligence

Remaining compliant with EU RoHS, especially exemption expirations and renewals, is cumbersome without the right tools to streamline the process. This challenge is amplified if your company is also obligated to meet additional global RoHS requirements, as each country has its own due diligence and reporting obligations. Utilizing powerful compliance management software can simplify your compliance processes and help you reduce risk in your supply chain.

When you partner with Source Intelligence, we take time to understand your unique needs to ensure you get the right solution for your business. Whether you want to purchase our industry-leading software to self-manage your RoHS compliance program or prefer to utilize our managed services so our experts can do the heavy lifting for you, we provide effective tools to streamline RoHS compliance in the EU and beyond.  

Interested in learning more? Explore the features and benefits of our global RoHS program, or schedule a demo to discover how we can help. 

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