Understanding RoHS Exempted Product Categories 2023

European Commission has created more than 100 exemptions for the current RoHS directive. RoHS exemption temporarily allows restricted substances to be used in certain applications when suitable alternatives are not currently available. There are 2 different RoHS exemption lists (RoHS exempted list) under the RoHS Directive. Annex III, impacting categories 1 through 11, and Annex IV, impacting categories 8 and 9, medical devices, and monitoring and control equipment. Exemptions are substance- and application-based for a specific period of time.

EU ROHS Exemptions list (Excel)

RoHS compliance is not required for the product categories mentioned below and is considered out-of-scope products. Out-of-scope products are of a specific type or category that are permitted to be shipped into the EU without any limits on the amount of the restricted substances they can contain. Products may be out of scope depending on the application or industry.

Electrical products that are used for space applications, will be out of scope for the foreseeable future. These products are excluded because they are typically used in a place that is difficult to access or is unlikely to be thrown into a landfill by the general public. Electrical or electronic equipment attached to these kinds of products typically needs professional help for removal or replacement, and safe disposal of the parts or components.

The specific products or applications that are out of the scope of RoHS are mentioned in Article 2(4), and they are not expected to be implemented within a specific timeframe.

Military – Equipment used for defense or national security. Equipment, such as arms, munitions, and war materials meant specifically for military use, is required to protect the member states’ security interests.

Space – Equipment designed to be sent into space such as satellites, telescopes, spacecraft

Transportation – vehicles used for transport (except 2-wheeled vehicles such as electric motorcycles, electric dirt bikes, and electric bicycles)

R&D equipment specifically designed and used solely for the purpose of professional research and development

Non-road mobile machinery (NRMM) – NRMM for professional use such as agricultural, railway, waterway, and construction machinery

Large-scale fixed installations (LSFI) – electrical distribution, HVAC, robotic equipment, and lines

Large-scale stationary industrial tools (LSSIT) – CNC, milling, metal-forming, testing machines; cranes

Fixed-location photovoltaic panel (PV) installations- Photovoltaic panels intended to be used in a system that is designed, assembled, and installed by professionals for permanent use at a fixed location to produce energy from solar light for the public, commercial, industrial and residential applications.

Active Implantable Medical Devices (AIMDs) – pacemakers, implanted defibrillators, insulin pumps

Sub-equipment for out-of-scope equipment

Batteries – just the cells, not external wiring

Compact fluorescent light bulbs/lamps

Spare parts for equipment in the market before RoHS took effect – applies to all except for Category 11 products