RoHS: are exemptions for lead, cadmium and mercury still justified?

There may soon be an update to the RoHS Directive, which has gradually restricted since 2003 the content of hazardous substances in electronic and electrical products.

Current revocation and renewed exemption requests under Annexes III and IV of Directive 2011/65/EU are being studied, regarding the use of lead, cadmium and mercury. Among the arguments: a transition occurring before stakeholders are fully prepared, an occasional lack of real alternatives (e.g. for certain LED applications), or the economic and environmental cost of equipment renewal.

Genuine concerns or lack of preparation and adaptation from the manufacturers?

Material and energy transitions, while necessary, do take time for an efficient, cost-saving and successful implementation. Comparable exemptions have previously been granted. The European Commission will now assess the current applications.

The consultation runs until 1 August 2026. For more information, see the consultation cases managed by the Öko-Institut and the insights from the Product Compliance Institute.

What is your view and your experience? Are these exemptions still needed, or is the industry now ready to move beyond them?