Oeko-Institut has announced the commencement of a new RoHS exemption review project, referred to as “Pack 29,” under Directive 2011/65/EU. The project will assess ten exemption renewal requests under Annex III concerning the use of mercury in special-purpose gas discharge lamps, alongside several exemption revocation requests under Annex IV related to leaded glass applications.

The project forms part of the European Commission’s ongoing review of exemptions under the RoHS Directive, which restricts the use of hazardous substances in electrical and electronic equipment (EEE). Existing exemptions are periodically reassessed to determine whether safer or technically viable alternatives have become available.

Annex III - Exemption Renewal Requests

The following mercury-related exemptions are currently under review:

• Ex. 1(f)-I – Lamps emitting mainly light in the ultraviolet spectrum: 5 mg Hg
• Ex. 2(b)(4)-II – Lamps emitting mainly light in the ultraviolet spectrum: 15 mg Hg
• Ex. 2(b)(4)-III – Emergency lamps: 15 mg Hg
• Ex. 4(a)-I – Mercury in low pressure non-phosphor coated discharge lamps up to 15 mg Hg
• Ex. 4(c) – Mercury in other High Pressure Sodium (Vapour) Lamps (three variants)
• Ex. 4(f)-II – Mercury in high pressure mercury vapour lamps used in projectors
• Ex. 4(f)-III – Mercury in high pressure mercury vapour lamps used for horticulture lighting
• Ex. 4(f)-IV – Mercury ultraviolet lamps

Annex IV - Exemption Revocation Requests

The following exemptions are proposed for revocation review:

• Ex. 1 – Lead, cadmium and mercury in detectors for ionising radiation
• Ex. 1a – Lead and cadmium in ion selective electrodes, including glass of pH electrodes
• Ex. 3 – Lead in electromagnetic radiation amplification devices, including micro-channel plates and capillary plates
• Monitor developments closely
• Evaluate any potential impact on compliance obligations, product design, and supply chain strategies

 According to Oeko-Institut, a stakeholder consultation had been expected to launch in May 2026.  Industry stakeholders, manufacturers, suppliers, and trade associations are encouraged to participate in the consultation process, as submitted technical and scientific evidence may contribute to the final recommendations presented to the European Commission.

Actions for companies affected by the exemptions under review

• Monitor developments closely
• Evaluate any potential impact on compliance obligations, product design, and supply chain strategies

Please contact the 1cc GmbH compliance team for support in understanding the implications of RoHS Directive compliance.