EU RoHS exemption - Application for extension of six mercury exemptions in fluorescent lamps rejected
On June 18, 2021, the European Commission issued two draft regulations to amend Annex III of rohs2.0 directive, to suspend and extend the validity of six mercury exemption provisions for fluorescent lamps, and to conduct a four week public consultation from now to July 16, 2021.
These six exemptions are: Items 1 (g) and 2 (a) (1) to 2 (a) (5).
According to the rohs2.0 directive, the application for extension or renewal of exemption should be submitted at least 18 months before the expiration of exemption. The European Commission has received three applications for extension of the above six exemptions within the specified time. After many discussions and evaluations, the European Commission considers that there are reliable mercury free alternatives for the types of lamps covered by the exemption, and the use of mercury free alternatives is scientifically and technically feasible, so it decides not to extend the validity of the six exemptions. According to the directive, a transitional period of 12-18 months from the date of the decision will be granted to those whose applications for renewal are rejected. Therefore, it is proposed to update the above six exemptions as follows:
| Number of items | Exemption proposal | Scope and period of application to be revised |
| 1 | The mercury content in single ended (compact) fluorescent lamps shall not exceed (per lamp): | |
| 1(g) | For general lighting < 30W and service life ≥ 20000h: 3.5mg | The authorization order will expire 18 months after it is passed |
| 2(a) | The mercury content of double ended linear fluorescent lamps for general lighting shall not exceed (per lamp): | |
| 2(a)(1) | Trichromatic fluorescent lamp with normal service life, diameter < 9mm (e.g. T2): 4mg | The authorization order will expire 12 months after it is passed |
| 2(a)(2) | Three primary color fluorescent lamps with normal service life, pipe diameter ≥ 9mm and ≤ 17mm (e.g. T5): 3mg | The authorization order will expire 18 months after it is passed |
| 2(a)(3) | Three primary color fluorescent lamps with normal service life, diameter > 17 mm and ≤ 28 mm (e.g. T8): 3.5 mg | The authorization order will expire 18 months after it is passed |
| 2(a)(4) | Three primary color fluorescent lamp with normal service life, pipe diameter > 28mm (e.g. T12): 3.5mg | The authorization order will expire 12 months after it is passed |
| 2(a)(5) | Long life (≥ 25000h) trichromatic fluorescent lamp: 5 mg | The authorization order will expire 12 months after it is passed |
GIG interpretation
The transitional period is 12 months (18 months in part) after the adoption of the draft regulation. After the transitional period, the mercury lamps covered by items 1 (g) and 2 (a) (1) to 2 (a) (5) will no longer apply the relevant exemption, and the limit requirements of rohs2.0 should be strictly implemented.
GIG recommendations
Relevant enterprises should pay attention to the dynamic laws and regulations, establish and improve the supply chain management system, timely replace the non-conforming materials, and ensure the compliance of export. GIG reminds electronic and electrical manufacturers to keep an eye on the revision of RoHS exemption, and avoid the change of product compliance status due to the update of exemption terms.