On the 15th of January the European Commission announced three amendments to Annex III and Annex IV of Directive 2011/65/EU, i.e. the exemption lists for general EEEs and specific to medical devices, and monitoring and control instruments of RoHS 2. Reference No.: G/TBT/N/EU/257, G/TBT/N/EU/258, G/TBT/N/EU/259.


In Annex III to Directive 2011/65/EU, point 39 is replaced by the following:

Amended exemptionsExempted usesExpires time
39(a)Cadmium in colour converting II-VI LEDs (< 10 μg Cd per mm2 of light-emitting area) for use in solid state illumination or display systemsExpires on 30 June 2017.
39(b)Cadmium in downshifting cadmium based semiconductor nanocrystal quantum dots for use in display lighting applications (< 0.2 μg Cd per mm2 of display screen area)Expires on 30 June 2018.

In Annex IV to Directive 2011/65/EU, the following point 41 & 42 are added:

Amended exemptionsExempted usesExpires time
41Lead as a thermal stabiliser in polyvinyl chloride (PVC) used as base material in amperometric, potentiometric and conductometric electrochemical sensors which are used in in-vitro diagnostic medical devices for the analysis of blood and other body fluids and body gases.Expires on 31 December 2018.
42Mercury in electric rotating connectors used in intravascular ultrasound imaging systems capable of high operating frequency(> 50MHz) modes of operation.Expires on 30 June 2019.

RoHS Exemption

Materials and components for specific applications shall be included in Annexes III and IV, provided that their elimination or substitution is scientifically or technically impracticable, the reliability of substitutes is not ensured, or the total negative environmental health and consumer safety impacts caused by substitution are likely to outweigh the total environmental health and consumer safety benefits.


The RoHS exemption list will be reviewed in line with scientific and technical advances. Manufacturers are recommended to update the exemption lists and look for new environmentally friendly substitutes, to make sure the compliance of products exported to the EU market.

Download the PDF version here