The RoHS and ELV Directives specify prohibited substances along with exemptions that permit the use of such materials in certain applications for limited time periods.
Exemptions are only granted if the following criteria are met:
- The substitution/elimination of a prohibited substance is either scientifically or technically not practical.
- The reliability of substitute products is not assured.
- The continued use of the prohibited substance poses less risk to the environment and the consumer’s health and safety than its substitution or elimination.
Exemptions are only granted for set time periods, but may be renewed on application. Companies can also apply to the EU Commission in Brussels for new exemptions. Fraunhofer IZM has been assessing such exemption applications since 2005.
In collaboration with Öko-Institut in Freiburg and Eunomia in the UK (since 2012), we determine whether new and continuing applications meet or, in the latter case, continue to meet the above criteria. Once assessment is complete, we provide the European Commission with a report and our recommendations. Applications for RoHS exemptions and the reports to the Commission, including the application assessments and recommendations, are publicly accessible.
Similarly, applications for exemption and reports relating to the ELV Directive are available for download from the Internet.