After the exemptions 6a-c and 7a-c (so-called Pack 22) according to Annex III of the RoHS Directive 2011/65/EU have already formally expired on July 21, 2021, the affected companies are waiting with anticipation for the decision of the European Commission on the extension of the exemptions. Now there is a little movement in the process again.
Back in December 2020, the Öko-Institut was commissioned to evaluate the exemptions. The consultants' report on Pack 22 was now published on January 13, 2022.
For many companies, exemption 6c – copper alloy containing up to 4 % lead by weight – is of particular interest. In this regard, the Öko-Institut has recommended that this be extended uniformly for all categories until July 21, 2026. Whether the Commission will follow this recommendation cannot be predicted. It will now consult the member states and the European Parliament and publish a draft delegated directive. It will be at least another 9 months before the final decision on the derogation is published. The derogation will remain in place at least until then.
You can read the recommendations on the other exemptions in the Öko-Institut report linked below.
Our material compliance experts will be happy to answer any questions you may have!