RoHS Exemption 6(a): Preparing for the Future

Question:

My company uses a material (12L14 steel) that currently falls under the Restriction of Hazardous Substances (RoHS) Directive exemption 6(a). What is the expiration date for that exemption, and should an alternative be sought?

Answer:

Exemptions under the RoHS Directive are intended to allow industry to find suitable alternatives to restricted substances in specific uses. Over time, exemptions may either be discontinued or further restricted to eventually remove the substance over threshold.

Most exemptions that expired on July 21, 2016, received a request for extension, which allowed them to remain active as these requests were processed. They were officially extended with a final recommended date within one year to 18 months of the official filing. Exemption 6(a) included an official expiration date of July 1, 2019, for categories 1–7 and 10. After that date, Exemption 6(a)-I became active, which encompasses 12L14 steel, and the original 6(a) exemption remained live for categories 8,9 and 11.

It is important to note that exemption 6(a)-I is only valid until July 21, 2021, and exemption requests must be submitted before January 21, 2020 (18 months before expiration). Several groups are working on extension requests for this exemption, and it is anticipated that these requests will be submitted ahead of the deadline.

Article current as of 2019-09-27.

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