Exemption (RoHS)

An exemption under RoHS Directive 2011/65/EU is a specific authorisation for the use of a restricted substance in a defined application or material where substitution is technically or scientifically impracticable, or where the negative environmental, health, or consumer safety impacts of substitutes would outweigh the benefits. Exemptions are listed in Annex III (all EEE categories) and Annex IV (medical devices and monitoring/control instruments only). Under Article 5, exemptions are time-limited and must be renewed. Renewal applications must be submitted at least 18 months before expiry. Following Directive (EU) 2025/2456 (December 12, 2025), exemption applications are submitted to ECHA.

Directive 2011/65/EU, Article 5, Annex III, Annex IV; Directive (EU) 2025/2456 (December 12, 2025).

Exemptions are essential compliance tools for industries where substitution of restricted substances is not yet technically feasible. Manufacturers must identify the specific Annex III or IV entry applicable to each use case, confirm the exemption has not expired, and apply it only to the exact application specified. Using a broader application of an exemption than its text permits is non-compliance. Tracking exemption expiry dates and planning renewal applications 18+ months in advance are critical risk management activities.