EU Introduces Lead and Cadmium Exemption for Recovered PVC in RoHS Directive

The European Commission has issued an amendment to the RoHS Directive (Directive 2011/65/EU) on January 10, 2024, known as Directive (EU) 2024/232. This amendment introduces a notable exemption for lead and cadmium in plastic profiles. The exemption applies to recovered rigid polyvinyl chloride (PVC) profiles that are used in electrical and electronic windows and doors.

Effective Date

The changes to the RoHS Directive have been in effect since January 30, 2024. Member States of the European Union will be required to implement these new regulations by August 1, 2024.

Exemption Reasoning

The RoHS Directive's Annex II prohibits the presence of cadmium and lead, setting maximum concentrations at 0.01% and 0.1%, respectively. However, exemptions were not granted for applications listed in Annexes III and IV until an application for exemption of cadmium and lead in electrical and electronic windows and doors containing recovered PVC was submitted by the end of December 2015. After thoroughly evaluating the proposal and considering the distinct challenges associated with recovered rigid PVC, a new amendment has been introduced that applies to electrical and electronic equipment falling under category II of Annex I to Directive 2011/65/EU (other electrical and electronic equipment).

Environmental and Safety Considerations

The exemption recognizes that replacing recovered PVC with other materials may pose a greater threat to the environment, human health, and consumer safety, as rigid PVC requires less energy and natural resources compared to virgin PVC. Article 5(1) of the RoHS Directive provides guidelines for such exemptions, considering the overall impact on sustainability and resource utilization.

Support for Sustainable Practices

The aim of this amendment is to find a middle ground between protecting the environment and practical considerations. The EU's goal is to promote sustainable practices in the industry while keeping safety and compliance in mind. To achieve this, lead and cadmium will be allowed in recovered PVC for certain applications.

Industry Impact

Manufacturers, distributors, and stakeholders in the electrical and electronic sectors are urged to familiarize themselves with these changes and ensure compliance within the specified timeline.