MedTech Europe have kindly provided EU RoHS exemption pack timelines.
Packs 22 & 27
- These Packs include:
- Annex III lead exemptions: 6(a) series*, 6(b) series*, 6(c)*, 7(a)*, 7(c)-I*, 7(c)-II*, 13(a), 13(b), 15, 18(b), 34, 42, 44
- Annex III cadmium exemptions: 8(b), 13(b)
- Annex IV lead exemptions: 1(a), 1(b), 1(c), 4, 10
- Annex IV cadmium exemption: 9
- Annex IV DEHP exemption: 46
- Note: Pack 22 exemptions are marked with an asterisk and Pack 27 exemptions include all the exemptions above (and some overlap below), specifically for categories 8 (MD & IVD), 9 and 11.
- Timeline:
- The consultant BIOIS’ recommendation to the Commission on Pack 27 is expected for May 2024.
- The draft delegated acts for all the exemptions above are going to be published for the 4-week public consultation at the end of 2024.
Packs 23 & 24
- These Packs include:
- Timeline: after the draft delegated acts for the exemptions in Packs 22 & 27 have been launched for a 4-week public consultation – i.e. Q1 2025.
Therefore, because of the overlap in exemptions in Packs 22 and 27, the Commission will first prioritize those for the draft delegated acts’ public consultation (end of 2024) and will subsequently follow with the remaining 23 & 24 afterward (2025).
