Dear members, please see the below update on progress with EU RoHS renewals proposed by the Umbrella project. Let me have any objections to MedTech Europe Co-Signing these exemption requests by CoB 4th July. Note that if successful these will apply to Northern Ireland, however to obtain similar exemptions for GB, separate applications under GB RoHS are required and there is currently still no equivalent to Umbrella project in the UK.
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Dear members,
I hope you are all well.
We are writing to seek your approval by 8 July EOB for MedTech Europe to co-sign the attached RoHS Annex III renewal requests for exemptions 6a-I, 6c, and 7a.
As communicated in previous months, the Umbrella Project has been working on preparing exemption renewal requests for a number of Annex III exemptions, and has so far prioritized the exemptions that were subject to public consultations earlier in 2025, namely the 6 a-c and 7a/c series. Medtech Europe prepared its input to these renewals in anticipation of this Umbrella Project workstream and had previously adopted its input to these exemptions, which we shared with the Umbrella Project.
Our recommendation to members would be to co-sign these exemptions – this follows the agreed mandate of the WG, and by participating in the Umbrella Project groups on these exemptions, we have ensured our input is well reflected in the dossiers. Please note that at this stage, the exemptions are up for a yes/no vote; changes are no longer possible. As MedTech Europe, we have actively attended the meetings of the various Umbrella Project WGs and ensured our input is integrated.
The remaining Umbrella Project exemptions, i.e. 4a-I, 4f-IV, 6a-II, 7c-I, will follow in the coming weeks in separate batches, as they are taking a bit more time to be finalized.
As a final note, the Umbrella Project received a written confirmation from the European Commission that renewals should only be submitted once the final delegated acts have been published in the EU Official Journal. The plan of the Umbrella Project is therefore to adopt these renewals now and submit them later in the year when the acts are published in the EU Official Journal. Based on the new expiry dates we will see (the Commission confirmed in their letter that they will give industry 18 months) there may be time for the Working Groups to make more edits to their renewal applications, if these are needed. The Umbrella Project would then need to restart the endorsement process for those renewal applications that were amended.
