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RoHS Directive (Restriction of the use of certain Hazardous Substances (RoHS)), which refers to directive 2011/65/EU, was published by the European Union (EU) aiming to reduce the amount of hazardous substances used in electrical and electronic products. Since then, several exemptions were granted to specific applications which are scientifically or technically infeasible to be replaced. 
The exemptions of RoHS 2.0 (2011/65/EU) are listed in Annex III and Annex IV. The exemptions in Annex III are suitable for all EEE. Meanwhile, the exemptions in Annex IV are only suitable for medical devices (category 8) and monitoring and control instruments (category 9). 

Recently, the Official Journal of the European Union has published (EU) 2019/1845 and (EU) 2019/1846 to amend the Annex III of 2011/65/EU. The directives shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union, and will be implemented on 1 May, 2020.

The exemption updates in Annex III are listed in the adjacent tables.

Table 1: Updated exemptions in Commission Delegated Directive (EU) 2019/1845 and (EU) 2019/1846

Exemptions Scope & Dates of Applicability
43

Bis(2-ethylhexyl) phthalate in rubber components in engine systems, designed for use in equipment that is not intended solely for consumer use and provided that no plasticised material comes into contact with human mucous membranes or into prolonged contact with human skin and the concentration value of bis(2-ethylhexyl) phthalate does not exceed:

  • 30 % by weight of the rubber for:
  1. gasket coatings;
  2. solid-rubber gaskets; or
  3. rubber components included in assemblies of at least three components using electrical, mechanical or hydraulic energy to do work, and attached to the engine
  • 10 % by weight of the rubber for rubber-containing components not referred to in point (a)

For the purposes of this entry, “prolonged contact with human skin” means continuous contact of more than 10 minutes duration or intermittent contact over a period of 30 minutes, per day.

Applies to categories 11, expires on 21 July 2024
 
44 Lead in solder of sensors, actuators, and engine control units of combustion engines within the scope of Regulation (EU) 2016/1628 of the European Parliament and of the Council, installed in equipment used at fixed positions while in operation which is designed for professionals, but also used by non-professional user Applies to categories 11, expires on 21 July 2024

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