EU Packs 19 and 20, Consultation request for New and Renewal RoHS Annex IV for DEHP, Lead and Cadmium


The scope of the current consultation concerns two exemption requests: one for exemption renewal and one for a new exemption.

The application for the renewal of exemption 12, Annex IV was submitted under the project “Pack 19”, the application for the new exemption is being evaluated under the project “Pack 20”. The requests of both packages are to be consulted upon together, under the current stakeholder consultation.

Oeko-Institut and Fraunhofer IZM, on behalf of the European Commission, has published the requests as worded by the applicant, therefore the applicant is solely responsible for the wording and supporting evidence it has provided.

How to submit a stakeholder contribution

The following general guidelines should be taken into account:

• Refer to the exemption request listed in Table 2-1 and have a clear reference as to the exemption number

• Take the questionnaires on the exemption requests into account (questionnaires available under the exemption request specific pages, accessible through this link, and select exemptions through the tabs on the left.)

• Clearly state whether the exemption requests are supported or whether no justification is apparent. To support your contribution, it is required to provide relevant technical and scientific evidence in accordance with the criteria listed in Article 5(1)(a). Explain the reasons why potential alternative materials, designs or processes are unsuitable with quantitative data wherever possible. If possible, provide photographs or diagrams to illustrate claims. Provision of third party data and information may be beneficial to further support your view. Sources of information should be referenced where possible.

• Provide your input to the consultation as early as possible in order to allow other stakeholders to comment.

• Exemptions to RoHS Directive cannot be justified on the basis of confidential information.

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