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

This consultation covers 5 RoHS exemption requests:

  • Exemption request 2013-1"Lead as thermal stabilizer in Polyvinyl Chloride (PVC) used as base for substrates in amperometric, potentiometric and conductometric electrochemical sensors"
  • Exemption request 2013-2 "Cadmium in color converting II-VI LEDs (< 10 μg Cd per mm2 of light-emitting area) for use in solid state illumination or display systems" (Request for renewal of Exemption 39 of Annex III of Directive 2011/65/EU)
  • Exemption request 2013-3 "Lead in solders used in boards of heart-lung machines" exemption to expire in 2017
  • Exemption request 2013-4 "Mercury used in high speed rotating electrical connectors (slip ring) with electrical conduction paths that have sealed liquid mercury, molecularly bonded to the contacts”
  • Exemption request 2013-5 "Cadmium in light control materials used for display devices"

Policy field(s):


Environment, Waste

Target group(s):


The consultation is targeted at the following groups:

  • EEE industry
  • EEE industry federations
  • Consultancies
  • Research institutions & universities
  • NGOs
  • Public administrations

The following representatives from these groups have currently registered on the list. This list will be updated regularly depending on new registrations of interested stakeholders.
> Download list of interested stakeholders

Period of consultation


                                    From 19/08/2013 to 11/11/2013

Objective of the consultation


The RoHS Directive (2002/95/EC) (RoHS 1) 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 2) will be evaluated on the basis of the criteria for exemptions in Art. 5 (1) (a) RoHS 2.

View the questionnaire

Reference documents and other, related consultations


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 2013-1 Request 2013-2, Request 2013-3, Request 2013-4 and Request 2013-5 contain further necessary information (e.g. questionnaire and results of former evaluations).

Contact details


responsible service

Öko-Institut e.V.




postal address

P.O. Box 17 71
D - 79017 Freiburg

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.

Register now

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 has been identified.

Protection of personal data

Specific privacy statement