Businesses must remain vigilant about changes to the EU RoHS regulatory landscape, including exemption expirations and renewals, to ensure EU RoHS compliance in 2025. Continue reading to learn more about these important updates and how to prepare for the year ahead.
What are the latest revisions to the EU RoHS Directive?
The proposal to add TBBP-A and MCCPs to the restricted substances list under the EU RoHS Directive has officially been abandoned as of Dec 10, 2024. While this change will not move forward, monitoring exemption expirations and renewals outlined in the directive remains essential for maintaining compliance. To help you stay ahead, our experts have outlined the most critical updates expected this year.
Proposed Substance Additions: TBBPA & MCCPs
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 have increased the number of restricted substances under EU RoHS from 10 to 12. However, as of December 2024, the proposal has been abandoned, and no further action is expected regarding these substances.
About TBBPA & MCCPs:
- TBBPA: A flame retardant commonly used to reduce the flammability of plastics and synthetic resins in consumer products, including electrical and electronic equipment parts. It was originally considered for the restricted substances list due to its classification as a known carcinogen and its potential to harm human health.
- MCCPs: Industrial chemicals 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 were proposed for restriction due to their expected bioaccumulative nature and environmental toxicity.
Feedback provided during the proposal's earlier stages remains available for reference, but no further feedback will be provided.
Exemption Expirations
Multiple exemptions contained in Annex III and Annex IV are set to expire in 2025 and are no longer renewable. Exemption expirations apply to all categories, including 8 (medical devices), 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:
- Annex III n. 45
- Annex IV n. 42
- Annex IV n. 49
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 28, 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 cannot be included on the article, it must be included on the packaging.
EU Member States should have adopted and published the necessary provisions by July 31st, 2024. The provisions applied on August 1st, 2024.
Directive (EU) 2024/1416
Directive (EU) 2024/1416, published on March 13, 2024, and effective from June 10, 2024, amends Directive 2011/65/EU.
Annex III to Directive 2011/65/EU is amended as follows:
- Entry 39(a) is replaced by cadmium selenide in downshifting cadmium-based semiconductor nanocrystal quantum dots for use in display lighting applications. All categories expire on November 21, 2025.
- Entry 39(b) is a new entry and inserts cadmium in downshifting semiconductor nanocrystal quantum dots directly deposited on LED semiconductor chips for use in display and projection applications. All categories expire on December 31, 2027.
Prepare for Changes to EU RoHS in 2025 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 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.
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