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

Consultation on the renewal/amendment of 3 RoHS exemptions listed in Annex III and on 3 requests for new exemptions:
Exemption 9b: “Lead in bearing shells and bushes for refrigerant-containing compressors, with a stated electrical power input of only 9 kW or lower for the HVACR industry, with expiry date three years after the publication of the amended RoHS Annex”;
Exemption 13a: ”Lead in white glasses used for optical applications”;
Exemption 13b: ”Cadmium and Lead in filter glasses and glasses used for reflectance standards”;
Exemption Request 2015-1: “Lead in thin film electronic sensor elements such as pyroelectric sensors or piezoelectric sensors”
Exemption Request 2015-2: “lead in high voltage cables and cable assemblies for a rated voltage higher than 250kV DC, containing up to 4% lead by weight” (for industrial monitoring and control instruments, Annex IV)
Exemption Request 2015-3: “lead as activator in the fluorescent powder (1% lead by weight or less) of discharge lamps when used as phototherapy lamps containing phosphors such as BSP (BaSi2O5:Pb) ” (Annex IV).

Policy field(s):


Environment, Waste

Target group(s):


Interested stakeholders, list available on consultation page

Period of consultation


From 24.04.2015 to 19.06.2015

Objective of the consultation


Six recently submitted requests for renewal/amendment of existing Annex III/Annex IV exemptions, from the substance restrictions of Directive 2011/65/EU (RoHS 2), will be evaluated on the basis of the criteria for exemptions in Art. 5 (1) (a) RoHS 2.

How to submit your contribution


Interested parties are invited to send their comments by e-mail, at latest on the 19 June 2015, to or by post to:

Oeko-Institut e.V.
Carl-Otto Gensch
P.O. Box 17 71
D - 79017 Freiburg

Received contributions will be published on the Internet. It is important to read the specific privacy statement attached to this consultation for information on how your personal data and contribution will be dealt with.

View the consultation document


See consultation page (2015 Consultation 1) available under

View the questionnaire


See questionnaires available under the exemption request specific pages, accessible through the following links:
Exemption 9b :
Exemption 13a :
Exemptions 13b :
Request 2015-1 :
Request 2015-2 :

Request 2015-3 :

Reference documents and other, related consultations

Contact details


responsible service

Oeko-Institut e.V.




postal address

P.O. Box 17 71
D - 79017 Freiburg

View the contributions


In the interest of transparency, organisations have been invited to provide the public with relevant information about themselves by registering in the Interest Representative Register and subscribing to its Code of Conduct. If the organisation is not registered, the submission is published separately from the registered organisations.

Results of consultation and next steps


Non-confidential information submitted during the consultation are posted on the EU CIRCABC website.
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 have been identified.

Protection of personal data

Specific privacy statement