Pack 27 Exemption Requests (Second set)

The objective of this contract is to provide a clear technical and scientific assessment for the following exemption requests (Pack 27) under the Directive 2011/65/EU (RoHS) in agreement with the Commission.

Important note: Many exemptions of this pack 27 were reviewed in 2021 and 2022 already. The European Commission (COM) wishes to assess in this current review round whether there are any substantial reasons in line with Art. 5(1)(a) against the adoption of the recommendations from these previous reviews to be applied to EEE of categories 8, 9 and 11. A complete reassessment of the scientific and technological status as to the substitution or elimination of the restricted substances is not part of the review of these exemptions.

No. Exemption wording Request(s) and supporting documents Clarification Questionnaire(s) Consultation Questionnaire Consultation Responses
2022-2 New request
Cadmium in Hersch cells for oxygen sensors used in industrial monitoring and control instruments, where sensitivity below 100 ppm is required
Ametek MOCON Ametek MOCON Download
III 8b Cadmium and its compounds in electrical contacts TMC, TMC SEA III 8b TMC Download MTE
III 13a Lead in white glasses used for optical applications TMC, TMC SEA III 13a TMC Download MTE
III 13b Cadmium and lead in filter glasses and glasses used for reflectance standards TMC, TMC SEA III 13b TMC Download MTE
III 34 Lead in cermet-based trimmer potentiometer elements TMC, TMC SEA III 34 TMC Download MTE
III 42 Lead in bearings and bushes of diesel or gaseous fuel-powered internal combustion engines applied in non-road professional use equipment:
  • with engine total displacement ≥ 15 litres; or
  • with engine total displacement < 15 litres and the engine is designed to operate in applications where the time between signal to start and full load is required to be less than 10 seconds; or regular maintenance is typically performed in a harsh and dirty outdoor environment, such as mining, construction, and agriculture applications.
EUROMOT, NAM Support Letter EUROMOT Download JCB, DEUTZ, Volvo Penta, EMA, Cummins, EGMF
III 44 Lead in the solder of sensors, actuators, and engine control units of combustion engines within the scope of Regulation (EU) 2016/1628, installed in equipment used at fixed positions while in operation, which is designed for professionals, but also used by non-professional users EUROMOT, NAM Support Letter EUROMOT Download JCB, DEUTZ, Volvo Penta, EMA, Cummins, EGMF
IV 4 Lead in glass frit of X-ray tubes and image intensifiers and lead in glass frit binder for assembly of gas lasers and for vacuum tubes that convert electromagnetic radiation into electrons TMC, TMC SEA IV 4 TMC Download
IV 9 Cadmium in helium-cadmium lasers JBCE JBCE Download
IV 46 Bis(2-ethylhexyl) phthalate (DEHP) in plastic components in MRI detector coils COCIR No clarifications needed Download