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EU Packs 19 and 20 Consultation Request for New and Renewal RoHS Annex IV for DEHP, Lead, and Cadmium

DEHP - blog


The scope of the current consultation concerns two exemption requests: one for exemption renewal and one for a new exemption as shown in the table.

The application for the renewal of exemption 12, Annex IV, was submitted under the Pack 19 project.

The application for the new exemption is being evaluated under Pack 20.

The requests of both packages are to be consulted upon together under the current stakeholder consultation

Oeko-Institut and Fraunhofer IZM – on behalf of the European Commission – have published the requests as worded by the applicant; therefore, the applicant is solely responsible for the wording and supporting evidence it has provided.

How to Submit a Stakeholder Contribution

The following general guidelines should be taken into account:

  • Refer to the exemption request listed in Table 2-1 and have a clear reference as to the exemption number.
  • Take the questionnaires on the exemption requests into account. Questionnaires are available under the exemption request specific pages, accessible at
  • Select exemption through the tabs on the left.
  • Clearly state whether the exemption requests are supported or whether no justification is apparent. To support your contribution, it is required to provide relevant technical and scientific evidence in accordance with the criteria listed in Article 5(1)(a). Explain the reasons why potential alternative materials, designs or processes are unsuitable with quantitative data wherever possible. If possible, provide photographs or diagrams to illustrate claims. Provision of third party data and information may be beneficial to further support your view. Sources of information should be referenced where possible.
  • Provide your input to the consultation as early as possible in order to allow other stakeholders to comment.
  • Exemptions to RoHS Directive cannot be justified on the basis of confidential information.

Brenda Baney is the founder of B Cubed Consulting, Inc.

More information on this and other regulations are available on AIAG’s Regulatory Updates C2P page, which automatically pulls in new and relevant content as it becomes available. The content is brought to you via Compliance & Risks and their knowledge partner network. 

The RSS feed-driven page is geared toward individuals involved with corporate responsibility and sustainability (CR/S), those performing quality functions that require reporting into IMDS, and all others dealing with global substances of concern and waste regulation. The page’s simple and straightforward format allows users to quickly skim through content if desired, but also makes it easy to find more information. Clicking on any particular update’s title takes the user to the source page, where more detail is available. Since the page populates with fresh content as regulations are updated and customer requirements change, the process of staying informed is made stress-free. Checking back often will help individuals stay up to date on the latest need-to-know regulations and requirements and stay better prepared for compliance challenges. Additionally, although new content appearing at the top of the page will displace older updates, the latter will still be readily available simply by scrolling down.

For more information, contact Lecedra Welch, AIAG’s program manager for environmental sustainability, at CR@aiag.org.



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