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Follow! Appendix III of the EU RoHS Directive adds an exemption clause



Follow! Appendix III of the EU RoHS Directive adds an exemption clause

On January 10, 2024, the European Commission issued Directive (EU) 2024/232 in the official gazette, aiming to revise Annex III of the EU RoHS Directive and add an exemption for cadmium and lead in plastic profiles for electrical and electronic doors and windows containing recycled rigid PVC. This exemption will take effect on the 20th day after its publication in the EU official gazette, which is January 31, 2024. Each member state should convert it into its own legislation by July 31, 2024.

term  Content

Cadmium and lead in plastic profiles, including mixtures produced from PVC waste (hereinafter referred to as "recycled hard PVC"), are used for electrical and electronic doors and windows. The concentration of cadmium in the recycled hard PVC material does not exceed 0.1% by weight and lead does not exceed 1.5%.

Starting from May 28, 2026, hard PVC recovered from electrical and electronic doors and windows can only be used for the production of new products in the categories specified in point 18 (a) to (d) of Annex XVII, item 63 of Regulation (EC) 1907/2006.

Suppliers of PVC products containing recycled hard PVC with a lead concentration equal to or greater than 0.1% (by weight of PVC) should clearly, clearly, and indelibly mark these products with a statement stating "lead content ≥ 0.1%" before placing them on the market. If the nature of the item cannot be marked on it, it should be marked on the packaging of the item.

Suppliers of PVC products containing recycled hard PVC should submit written evidence to national law enforcement agencies as required to confirm the source of recycled PVC in these products. A certificate issued by the plan to demonstrate traceability and recyclability of ingredients, such as a certificate developed according to EN 15343:2007 or equivalent recognized standards, can be used to confirm such claims for PVC products produced in the European Union. The declaration of the origin of recycled PVC in imported goods should be accompanied by a certificate issued by an independent third party, providing equivalent proof of traceability and recycled ingredients.

Regulatory background

On December 14, 2015, the European Commission received an application for exemption from cadmium and lead in electric doors and windows containing recycled PVC in Annex III of the RoHS Directive. After evaluating the application, it was concluded that the use of recycled PVC requires less energy and natural resources than the use of lead-free and cadmium free native PVC, meets one of the relevant conditions specified in point 5 (1) (a) of the RoHS Directive, and does not weaken the environmental and health protection provided by the REACH regulations. Therefore, this exemption is approved. The exemption will expire on May 28, 2028.

Regarding the RoHS Directive Exemption Clause

Before the expiration of the exemption clause, enterprises or industry organizations may apply to the European Commission for an extension of the exemption validity period (18 months in advance). The European Commission will evaluate the received extension application and decide whether to extend or revise the exemption clause.

Regarding the validity period of RoHS directive exemption clauses

If no relevant party applies for an extension, the clause will automatically become invalid upon expiration; An enterprise or industry organization has applied for an extension, and this clause remains valid during the official evaluation period;

-If an extension is approved, the official will provide a new validity period;

-If the application for extension of the exemption clause is rejected or the exemption clause is revoked, the clause will expire for 12 to 18 months from the date of the decision.


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