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“Assistance to the Commission on technological, socio-economic and cost-benefit assessment related to exemptions from the substance restrictions in electrical and electronic equipment (RoHS Directive)”

Consultation on 18 RoHS 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)”

Policy field(s)

Environment, Waste

Target group(s)

Interested stakeholders, list available on consultation page

Period of consultation

                                    From 24.1.2012 to 20.3.2012

Objective of the consultation

The RoHS Directive (2002/95/EC) (RoHS I) has been recasted and has now become Directive 2011/65/EU that entered into force on 21 July 2011 and will lead to the repeal of Directive 2002/95/EC on 3 January 2013. Recently submitted requests for exemptions from the substance restrictions of Directive 2011/65/EU (RoHS II) will be evaluated on the basis of the criteria for exemptions in Art. 5 (1) (a) RoHS II.

View the consultation document

View the questionnaire

Reference documents and other, related consultations

Contact details

responsible service

Öko-Institut e.V.


postal address

P.O. Box 17 71
D - 79017 Freiburg

Number of responses received to this consultation

View the contributions

In the interests 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

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