The European Commission published an updated “Exemptions list – validity and rolling plan” document page (with an associated XLSX download) for RoHS Annex III/IV exemptions. While not itself a legal amendment, this Commission-hosted tracker is an authoritative compliance management resource for monitoring exemption validity periods, expirations, and the rolling plan of exemptions under review—supporting 2026 redesign/substitution planning, documentation updates, and exemption renewal tracking.
The European Commission’s RoHS implementation page consolidates operational guidance on the Article 5 exemptions process, including: exemption renewal applications must be submitted no later than 18 months before expiry; exemptions remain valid if a renewal request is timely until the Commission takes a decision; if renewal is rejected, a 12–18 month transition period typically applies; and decisions generally take 18–24 months from application. The page also records recent stakeholder consultation activity (e.g., “Pack 28” consultation window). Compliance teams can use this for planning exemption renewal submissions, managing continued market access during pending decisions, and scheduling redesign/substitution timelines when renewals may be denied.
The European Commission initiated an infringement procedure (letter of formal notice) against Cyprus for not transposing Commission Delegated Directive (EU) 2024/1416, which amends the RoHS Directive (2011/65/EU) by narrowing the scope of a cadmium-related exemption for certain LED applications due to technical progress. This signals heightened enforcement attention on Member State transposition of RoHS delegated directives, which can affect consistent EU market access and national enforcement posture.
The European Commission opened infringement procedures (letters of formal notice) against Portugal and Slovakia for failure to communicate national transposition measures for Commission Delegated Directive (EU) 2024/232 by the required deadline stated in the research text (31 July 2024). The delegated directive amends RoHS to enable certain uses of recovered rigid PVC in plastic profiles for electrical/electronic windows and doors under specified conditions (including cadmium and lead concentration limits and marking/traceability requirements as described in the research text). This enforcement action is relevant for companies relying on Member State implementation of the exemption and indicates increased Commission scrutiny on timely transposition of RoHS delegated directives.