RoHS restricts ten substances, but some uses still have no viable substitute. For those, the directive grants time-limited exemptions, each with a precise scope and expiry date. They sit in Annex III (general) and Annex IV (medical devices and monitoring & control instruments).
Full Annex III & IV, verify expiry dates at the source
This lists the full set of Annex III and Annex IV exemptions and sub-entries from the consolidated directive. Expiry dates are deliberately omitted because they vary by product category and are amended frequently; entries marked "(expired)" had lapsed in the source. Always confirm the exact wording, scope and validity in the consolidated directive on EUR-Lex (source link in the table).
157 of 157 shownSource: EUR-Lex — Directive 2011/65/EU (consolidated) ↗
| Ref | Annex | Substance | Scope |
|---|---|---|---|
| 1(a) | Annex III | Mercury | Mercury in single capped (compact) fluorescent lamps for general lighting <30 W: 2,5 mg per burner (expired) |
| 1(b) | Annex III | Mercury | Mercury in single capped CFLs for general lighting >=30 W and <50 W: 3,5 mg per burner (expired) |
| 1(c) | Annex III | Mercury | Mercury in single capped CFLs for general lighting >=50 W and <150 W: 5 mg per burner (expired) |
| 1(d) | Annex III | Mercury | Mercury in single capped CFLs for general lighting >=150 W: 15 mg per burner (expired) |
| 1(e) | Annex III | Mercury | Mercury in single capped CFLs for general lighting, circular/square shape, tube diameter <=17 mm: 5 mg (expired) |
| 1(f)-I | Annex III | Mercury | Mercury in single capped CFLs designed to emit mainly ultraviolet light: 5 mg per burner |
| 1(f)-II | Annex III | Mercury | Mercury in single capped CFLs for special purposes: 5 mg per burner |
| 1(g) | Annex III | Mercury | Mercury in single capped CFLs for general lighting <30 W with lifetime >=20000 h: 3,5 mg (expired) |
| 2(a)(1) | Annex III | Mercury | Mercury in double-capped linear fluorescent lamps, tri-band phosphor normal lifetime, tube <9 mm (e.g. T2): 4 mg (expired) |
| 2(a)(2) | Annex III | Mercury | Mercury in double-capped linear fluorescent lamps, tri-band normal lifetime, tube 9-17 mm (e.g. T5): 3 mg (expired) |
| 2(a)(3) | Annex III | Mercury | Mercury in double-capped linear fluorescent lamps, tri-band normal lifetime, tube 17-28 mm (e.g. T8): 3,5 mg (expired) |
| 2(a)(4) | Annex III | Mercury | Mercury in double-capped linear fluorescent lamps, tri-band normal lifetime, tube >28 mm (e.g. T12): 3,5 mg (expired) |
| 2(a)(5) | Annex III | Mercury | Mercury in double-capped linear fluorescent lamps, tri-band long lifetime (>=25000 h): 5 mg (expired) |
| 2(b)(1) | Annex III | Mercury | Mercury in linear halophosphate lamps with tube >28 mm (e.g. T10, T12): 10 mg (expired) |
| 2(b)(2) | Annex III | Mercury | Mercury in non-linear halophosphate lamps (all diameters): 15 mg (expired) |
| 2(b)(3) | Annex III | Mercury | Mercury in non-linear tri-band phosphor lamps with tube >17 mm (e.g. T9): 15 mg (expired) |
| 2(b)(4)-I | Annex III | Mercury | Mercury in lamps for other general lighting and special purposes (e.g. induction lamps): 15 mg (expired) |
| 2(b)(4)-II | Annex III | Mercury | Mercury in lamps emitting mainly ultraviolet light: 15 mg per lamp |
| 2(b)(4)-III | Annex III | Mercury | Mercury in emergency lamps: 15 mg per lamp |
| 3(a) | Annex III | Mercury | Mercury in CCFL and EEFL for special purposes (pre-2022 EEE), short length <=500 mm: 3,5 mg (expired) |
| 3(b) | Annex III | Mercury | Mercury in CCFL and EEFL for special purposes, medium length 500-1500 mm: 5 mg (expired) |
| 3(c) | Annex III | Mercury | Mercury in CCFL and EEFL for special purposes, long length >1500 mm: 13 mg (expired) |
| 4(a) | Annex III | Mercury | Mercury in other low pressure discharge lamps: 15 mg per lamp (expired) |
| 4(a)-I | Annex III | Mercury | Mercury in low pressure non-phosphor coated discharge lamps where main output is in ultraviolet spectrum: up to 15 mg per lamp |
| 4(b) | Annex III | Mercury | Mercury in High Pressure Sodium vapour lamps, improved CRI Ra>80, P<=105 W: 16 mg per burner |
| 4(b)-I | Annex III | Mercury | Mercury in High Pressure Sodium vapour lamps, improved CRI Ra>60, P<=155 W: 30 mg per burner (expired) |
| 4(b)-II | Annex III | Mercury | Mercury in High Pressure Sodium vapour lamps, improved CRI Ra>60, 155-405 W: 40 mg per burner (expired) |
| 4(b)-III | Annex III | Mercury | Mercury in High Pressure Sodium vapour lamps, improved CRI Ra>60, P>405 W: 40 mg per burner (expired) |
| 4(c)-I | Annex III | Mercury | Mercury in other High Pressure Sodium vapour lamps for general lighting, P<=155 W: 20 mg per burner |
| 4(c)-II | Annex III | Mercury | Mercury in other High Pressure Sodium vapour lamps for general lighting, 155-405 W: 25 mg per burner |
| 4(c)-III | Annex III | Mercury | Mercury in other High Pressure Sodium vapour lamps for general lighting, P>405 W: 25 mg per burner |
| 4(d) | Annex III | Mercury | Mercury in High Pressure Mercury vapour lamps (HPMV) (expired) |
| 4(e) | Annex III | Mercury | Mercury in metal halide lamps (MH) |
| 4(f)-I | Annex III | Mercury | Mercury in other discharge lamps for special purposes not specifically mentioned in this Annex (expired) |
| 4(f)-II | Annex III | Mercury | Mercury in high pressure mercury vapour lamps used in projectors requiring output >=2000 lumen ANSI |
| 4(f)-III | Annex III | Mercury | Mercury in high pressure sodium vapour lamps used for horticulture lighting |
| 4(f)-IV | Annex III | Mercury | Mercury in lamps emitting light in the ultraviolet spectrum |
| 4(g) | Annex III | Mercury | Mercury in hand crafted luminous discharge tubes for signs, decorative, architectural and light-artwork lighting (expired) |
| 5(a) | Annex III | Lead | Lead in glass of cathode ray tubes |
| 5(b) | Annex III | Lead | Lead in glass of fluorescent tubes not exceeding 0,2% by weight |
| 6(a) | Annex III | Lead | Lead as alloying element in steel for machining and in galvanised steel up to 0,35% by weight (expired) |
| 6(a)-I | Annex III | Lead | Lead in steel for machining up to 0,35% and in batch hot dip galvanised steel components up to 0,2% by weight (expired) |
| 6(b) | Annex III | Lead | Lead as alloying element in aluminium containing up to 0,4% lead by weight (expired) |
| 6(b)-I | Annex III | Lead | Lead as alloying element in aluminium up to 0,4% by weight from lead-bearing aluminium scrap recycling (expired) |
| 6(b)-II | Annex III | Lead | Lead as alloying element in aluminium for machining purposes up to 0,4% by weight (expired) |
| 6(c) | Annex III | Lead | Copper alloy containing up to 4% lead by weight (expired) |
| 7(a) | Annex III | Lead | Lead in high melting temperature type solders (lead-based alloys containing >=85% lead by weight) (expired) |
| 7(b) | Annex III | Lead | Lead in solders for servers, storage, network infrastructure equipment for telecommunications |
| 7(c)-I | Annex III | Lead | Lead in glass or ceramic (other than dielectric ceramic capacitors), e.g. piezoelectronic devices, or glass/ceramic matrix compound (expired) |
| 7(c)-II | Annex III | Lead | Lead in dielectric ceramic in capacitors rated 125 V AC or 250 V DC or higher (expired) |
| 7(c)-III | Annex III | Lead | Lead in dielectric ceramic in capacitors rated less than 125 V AC or 250 V DC (expired) |
| 7(c)-IV | Annex III | Lead | Lead in PZT-based dielectric ceramic materials for capacitors part of integrated circuits or discrete semiconductors (expired) |
| 8(a) | Annex III | Cadmium | Cadmium and its compounds in one shot pellet type thermal cut-offs (expired) |
| 8(b) | Annex III | Cadmium | Cadmium and its compounds in electrical contacts (categories 8, 9, 11) (expired) |
| 8(b)-I | Annex III | Cadmium | Cadmium and its compounds in electrical contacts in circuit breakers, thermal controls, motor protectors and certain switches (expired) |
| 9 | Annex III | Hex. chromium | Hexavalent chromium as anticorrosion agent in carbon steel cooling system of absorption refrigerators up to 0,75% by weight (expired) |
| 9(a)-I | Annex III | Hex. chromium | Up to 0,75% hex. chromium anticorrosion in absorption refrigerators with electrical heater, power input <75 W (expired) |
| 9(a)-II | Annex III | Hex. chromium | Up to 0,75% hex. chromium anticorrosion in absorption refrigerators with electrical heater >=75 W or non-electrical heater (expired) |
| 9(a)-III | Annex III | Hex. chromium | Up to 0,7% hex. chromium anticorrosion in carbon steel sealed circuit of gas absorption heat pumps for space/water heating (expired) |
| 9(b) | Annex III | Lead | Lead in bearing shells and bushes for refrigerant-containing compressors for HVACR applications (expired) |
| 9(b)-I | Annex III | Lead | Lead in bearing shells and bushes for refrigerant-containing hermetic scroll compressors <=9 kW for HVACR applications (expired) |
| 11(a) | Annex III | Lead | Lead used in C-press compliant pin connector systems; spare parts only for pre-24 Sep 2010 EEE (expired) |
| 11(b) | Annex III | Lead | Lead used in other than C-press compliant pin connector systems (expired) |
| 12 | Annex III | Lead | Lead as coating material for the thermal conduction module C-ring; spare parts only for pre-24 Sep 2010 EEE (expired) |
| 13(a) | Annex III | Lead | Lead in white glasses used for optical applications (expired) |
| 13(b) | Annex III | Pb/Cd | Cadmium and lead in filter glasses and glasses used for reflectance standards (categories 8, 9, 11) (expired) |
| 13(b)-I | Annex III | Lead | Lead in ion coloured optical filter glass types (expired) |
| 13(b)-II | Annex III | Cadmium | Cadmium in striking optical filter glass types; excluding applications under point 39 |
| 13(b)-III | Annex III | Pb/Cd | Cadmium and lead in glazes used for reflectance standards |
| 14 | Annex III | Lead | Lead in solders of more than two elements connecting pins and package of microprocessors, 80-85% lead by weight (expired) |
| 15 | Annex III | Lead | Lead in solders for electrical connection between semiconductor die and carrier within IC flip chip packages (expired) |
| 15(a) | Annex III | Lead | Lead in solders for die-carrier connection in IC flip chip packages meeting node/die-size criteria (categories 1-7,10) (expired) |
| 16 | Annex III | Lead | Lead in linear incandescent lamps with silicate coated tubes (expired) |
| 17 | Annex III | Lead | Lead halide as radiant agent in high intensity discharge (HID) lamps for professional reprography applications |
| 18(a) | Annex III | Lead | Lead as activator in fluorescent powder of discharge lamps for diazoprinting, lithography, insect traps, photochemical/curing (expired) |
| 18(b) | Annex III | Lead | Lead as activator in fluorescent powder of discharge lamps used as sun tanning lamps (BSP phosphors) (expired) |
| 18(b)-I | Annex III | Lead | Lead as activator in fluorescent powder (BSP phosphors) of discharge lamps used in medical phototherapy equipment (expired) |
| 19 | Annex III | Lead | Lead with PbBiSn-Hg/PbInSn-Hg as main amalgam and PbSn-Hg auxiliary amalgam in very compact energy saving lamps (expired) |
| 20 | Annex III | Lead | Lead oxide in glass bonding front and rear substrates of flat fluorescent lamps used for LCDs (expired) |
| 21 | Annex III | Pb/Cd | Lead and cadmium in printing inks for enamels on glasses such as borosilicate and soda lime glasses (expired) |
| 21(a) | Annex III | Cadmium | Cadmium in colour printed glass for filtering, used in lighting in displays and control panels of EEE (expired) |
| 21(b) | Annex III | Cadmium | Cadmium in printing inks for enamels on glasses such as borosilicate and soda lime glasses (categories 1-7,10) (expired) |
| 21(c) | Annex III | Lead | Lead in printing inks for enamels on other than borosilicate glasses (categories 1-7,10) (expired) |
| 23 | Annex III | Lead | Lead in finishes of fine pitch components other than connectors with pitch 0,65 mm and less; spare parts only (expired) |
| 24 | Annex III | Lead | Lead in solders for soldering machined through hole discoidal and planar array ceramic multilayer capacitors (expired) |
| 25 | Annex III | Lead | Lead oxide in surface conduction electron emitter displays (SED), notably in seal frit and frit ring |
| 26 | Annex III | Lead | Lead oxide in the glass envelope of black light blue lamps (expired) |
| 27 | Annex III | Lead | Lead alloys as solder for transducers in high-powered loudspeakers (>=125 dB SPL) (expired) |
| 29 | Annex III | Lead | Lead bound in crystal glass as defined in Council Directive 69/493/EEC categories 1-4 (expired) |
| 30 | Annex III | Cadmium | Cadmium alloys as electrical/mechanical solder joints on voice coil in transducers in high-powered loudspeakers (>=100 dB(A)) |
| 31 | Annex III | Lead | Lead in soldering materials in mercury free flat fluorescent lamps (e.g. LCD, design or industrial lighting) |
| 32 | Annex III | Lead | Lead oxide in seal frit for making window assemblies for Argon and Krypton laser tubes (expired) |
| 33 | Annex III | Lead | Lead in solders for soldering thin copper wires of 100 um diameter and less in power transformers |
| 34 | Annex III | Lead | Lead in cermet-based trimmer potentiometer elements (expired) |
| 36 | Annex III | Mercury | Mercury as cathode sputtering inhibitor in DC plasma displays, up to 30 mg per display (expired) |
| 37 | Annex III | Lead | Lead in the plating layer of high voltage diodes on the basis of a zinc borate glass body (expired) |
| 38 | Annex III | Cadmium | Cadmium and cadmium oxide in thick film pastes used on aluminium bonded beryllium oxide |
| 39(a) | Annex III | Cadmium | Cadmium selenide in downshifting Cd-based semiconductor nanocrystal quantum dots for display lighting (<0,2 ug Cd/mm2) (expired) |
| 40 | Annex III | Cadmium | Cadmium in photoresistors for analogue optocouplers applied in professional audio equipment (expired) |
| 41 | Annex III | Lead | Lead in solders/finishes of components and PCBs in ignition modules and engine control systems of hand-held combustion engines (expired) |
| 42 | Annex III | Lead | Lead in bearings and bushes of diesel or gaseous fuel internal combustion engines in non-road professional use equipment (expired) |
| 43 | Annex III | DEHP | Bis(2-ethylhexyl) phthalate in rubber components in engine systems for non-consumer equipment within concentration limits (expired) |
| 44 | Annex III | Lead | Lead in solder of sensors, actuators and engine control units of combustion engines per Reg (EU) 2016/1628, fixed-position equipment (expired) |
| 45 | Annex III | Pb/Cr | Lead azide/styphnate/dipicramate/tetroxide/dioxide in electric initiators of civil explosives and barium chromate in pyrotechnic delay charges (expired) |
| 46 | Annex III | Pb/Cd | Cadmium and lead in plastic profiles from recovered rigid PVC waste for electrical/electronic windows and doors within concentration limits (expired) |
| 1 | Annex IV | Pb/Cd/Hg | Lead, cadmium and mercury in detectors for ionising radiation |
| 1(a) | Annex IV | Pb/Cd | Lead and cadmium in ion selective electrodes including glass of pH electrodes |
| 1(b) | Annex IV | Lead | Lead anodes in electrochemical oxygen sensors |
| 1(c) | Annex IV | Pb/Cd/Hg | Lead, cadmium and mercury in infra-red light detectors |
| 1(d) | Annex IV | Mercury | Mercury in reference electrodes: low chloride mercury chloride, mercury sulphate and mercury oxide (expired) |
| 2 | Annex IV | Lead | Lead bearings in X-ray tubes |
| 3 | Annex IV | Lead | Lead in electromagnetic radiation amplification devices: micro-channel plate and capillary plate |
| 4 | Annex IV | Lead | Lead in glass frit of X-ray tubes and image intensifiers and in glass frit binder for gas lasers and vacuum tubes (expired) |
| 5 | Annex IV | Lead | Lead in shielding for ionising radiation |
| 6 | Annex IV | Lead | Lead in X-ray test objects (expired) |
| 7 | Annex IV | Lead | Lead stearate X-ray diffraction crystals (expired) |
| 8 | Annex IV | Cadmium | Radioactive cadmium isotope source for portable X-ray fluorescence spectrometers (expired) |
| 9 | Annex IV | Cadmium | Cadmium in helium-cadmium lasers (expired) |
| 10 | Annex IV | Pb/Cd | Lead and cadmium in atomic absorption spectroscopy lamps (expired) |
| 11 | Annex IV | Lead | Lead in alloys as a superconductor and thermal conductor in MRI |
| 12 | Annex IV | Pb/Cd | Lead and cadmium in metallic bonds creating superconducting magnetic circuits in MRI, SQUID, NMR or FTMS detectors (expired) |
| 13 | Annex IV | Lead | Lead in counterweights |
| 14 | Annex IV | Lead | Lead in single crystal piezoelectric materials for ultrasonic transducers |
| 15 | Annex IV | Lead | Lead in solders for bonding to ultrasonic transducers |
| 16 | Annex IV | Mercury | Mercury in very high accuracy capacitance and loss measurement bridges and high frequency RF switches/relays, <=20 mg per switch |
| 17 | Annex IV | Lead | Lead in solders in portable emergency defibrillators |
| 18 | Annex IV | Lead | Lead in solders of high performance infrared imaging modules detecting in the range 8-14 micrometre |
| 19 | Annex IV | Lead | Lead in Liquid crystal on silicon (LCoS) displays |
| 20 | Annex IV | Cadmium | Cadmium in X-ray measurement filters |
| 21 | Annex IV | Cadmium | Cadmium in phosphor coatings in image intensifiers for X-ray images and spare parts for pre-2020 X-ray systems (expired) |
| 22 | Annex IV | Lead | Lead acetate marker for stereotactic head frames with CT and MRI and positioning systems for gamma beam and particle therapy (expired) |
| 23 | Annex IV | Lead | Lead as alloying element for bearings and wear surfaces in medical equipment exposed to ionising radiation (expired) |
| 24 | Annex IV | Lead | Lead enabling vacuum tight connections between aluminium and steel in X-ray image intensifiers (expired) |
| 25 | Annex IV | Lead | Lead in surface coatings of nonmagnetic pin connector systems used durably below -20 degrees C (expired) |
| 26 | Annex IV | Lead | Lead in solders, coatings and connections on PCBs, wires, transducers and sensors used durably below -20 degrees C (expired) |
| 27 | Annex IV | Lead | Lead in solders, coatings, connections, shields and connectors used in magnetic fields near MRI or cyclotron/particle-therapy magnets (expired) |
| 28 | Annex IV | Lead | Lead in solders mounting cadmium telluride and cadmium zinc telluride digital array detectors to printed circuit boards (expired) |
| 29 | Annex IV | Lead | Lead in alloys as superconductor or thermal conductor in cryo-cooler cold heads, cryo-cooled probes and equipotential bonding (expired) |
| 30 | Annex IV | Hex. chromium | Hexavalent chromium in alkali dispensers creating photocathodes in X-ray image intensifiers and spare parts for pre-2020 systems (expired) |
| 31 | Annex IV | Pb/Cd/CrVI | Lead, cadmium and hexavalent chromium in reused spare parts recovered from pre-22 July 2014 medical devices in closed-loop systems (expired) |
| 31(a) | Annex IV | Pb/Cd/CrVI/PBDE | Lead, cadmium, hexavalent chromium and PBDE in spare parts reused to repair medical devices or electron microscopes in closed-loop systems |
| 32 | Annex IV | Lead | Lead in solders on PCBs of detectors and data acquisition units for Positron Emission Tomographs integrated into MRI equipment (expired) |
| 33 | Annex IV | Lead | Lead in solders on populated PCBs in class IIa and IIb mobile medical devices other than portable defibrillators (expired) |
| 34 | Annex IV | Lead | Lead as activator in fluorescent powder of discharge lamps for extracorporeal photopheresis lamps containing BSP phosphors (expired) |
| 35 | Annex IV | Mercury | Mercury in cold cathode fluorescent lamps for LCD backlighting, <=5 mg per lamp, in pre-22 July 2017 industrial monitoring instruments |
| 36 | Annex IV | Lead | Lead in non-C-press compliant pin connector systems for industrial monitoring and control instruments (expired) |
| 37 | Annex IV | Lead | Lead in platinized platinum electrodes for conductivity measurements requiring wide range, high accuracy/corrosion resistance, or portable use |
| 38 | Annex IV | Lead | Lead in solder in one interface of large area stacked die elements with over 500 interconnects in CT and X-ray detectors (expired) |
| 39 | Annex IV | Lead | Lead in micro-channel plates (MCPs) used in equipment requiring compact size, specific spatial resolution, response time or multiplication factor |
| 40 | Annex IV | Lead | Lead in dielectric ceramic in capacitors rated below 125 V AC or 250 V DC for industrial monitoring and control instruments (expired) |
| 41 | Annex IV | Lead | Lead as thermal stabiliser in PVC base material in electrochemical sensors in in-vitro diagnostic devices for blood, body fluids and gases (expired) |
| 42 | Annex IV | Mercury | Mercury in electric rotating connectors in intravascular ultrasound imaging systems with high operating frequency (>50 MHz) modes |
| 43 | Annex IV | Cadmium | Cadmium anodes in Hersch cells for oxygen sensors in industrial monitoring instruments where sensitivity below 10 ppm is required (expired) |
| 44 | Annex IV | Cadmium | Cadmium in radiation tolerant video camera tubes for cameras over 450 TV lines used in high ionising radiation environments |
| 45 | Annex IV | DEHP | DEHP in ion-selective electrodes for point of care analysis of ionic substances in human body fluids and/or dialysate fluids |
| 46 | Annex IV | DEHP | Bis(2-ethylhexyl) phthalate (DEHP) in plastic components in MRI detector coils (expired) |
| 47 | Annex IV | DEHP/BBP/DBP/DIBP | DEHP, BBP, DBP and DIBP in spare parts reused to repair medical devices and accessories in closed-loop business-to-business return systems |
Full RoHS Annex III (general) and Annex IV (medical devices and monitoring/control instruments) exemptions from Directive 2011/65/EU, compiled from the EUR-Lex consolidated text (version 02011L0065-20240801) and authoritative reproductions. Pareo maintains this by hand. Expiry dates are left out on purpose: each one depends on the product category and changes often. Entries marked '(expired)' had already lapsed in the source. Confirm scope and validity in the consolidated directive on EUR-Lex.
How exemptions work
Where they live
Annex III (general) and Annex IV (medical / M&C instruments)
Nature
Time-limited, each has an expiry date
Renewal
Industry must apply to renew before expiry
If expired
The use must comply or stop unless renewed
Tip
Track the expiry dates of every exemption your products rely on. A lapsing exemption is a common and avoidable cause of non-compliance, so plan substitution or renewal well ahead.