The stakeholder consultation on the RoHS exemption renewal application for Mercury UV lamps (Exemption 4(f)-IV) closed on 2 August 2026.
Key developments:
- 94 stakeholder responses have been published as part of the consultation process.
- RadTech Europe (RTE) submitted a response supporting the renewal application and highlighting the continued need for mercury UV lamp technology in specific industrial applications.
- The consultation phase is now complete, and the application has moved into the evaluation and decision-making stage.
Why It Matters
The publication of stakeholder responses marks an important milestone in the renewal process. The volume of submissions demonstrates strong stakeholder engagement and provides the evidence base that will be assessed by the consultants and the European Commission. Importantly, the exemption remains under review and no decision has yet been taken.
The current RoHS exemption expiry date of February 2027 does not prevent continued market access while the renewal application is being evaluated.
Under the RoHS exemption renewal process:
- Mercury UV lamps covered by Exemption 4(f)-IV may continue to be placed on the EU market while a decision on the renewal application is pending.
- Equipment containing these lamps may continue to be used during the review period.
- The existing exemption remains applicable until the European Commission formally adopts a decision.
This provides regulatory continuity for manufacturers, system suppliers, and users while the review process is completed.
What Happens Next?
The remaining steps in the process are:
- Assessment by Oeko-Institut
- Review of stakeholder submissions.
- Additional stakeholder exchanges or technical discussions, if required.
- Preparation of the final consultant assessment report and submission to European Commission.
- European Commission Evaluation
- Consideration of the consultant's recommendations and supporting evidence and drafting of Delegated Directive
- RoHS Expert Group Comitology Process
- Discussion and consultation with Member State experts.
- Adoption of Delegated Directive by European Commission
- Formal adoption of the Commission's decision regarding the exemption renewal.
- Two-month scrutiny period by European Parliament and Council for possible objections
What Members Should Do
Continue Normal Business Operations
Mercury UV lamps covered by Exemption 4(f)-IV can continue to be placed on the EU market, and installed equipment can continue to be used and supported while the renewal decision is pending.
Monitor Regulatory Developments
The consultation phase has concluded, but several important decision-making steps remain. Members should continue monitoring updates from industry associations and the European Commission.
Collect Technical and Market Evidence
Companies should collect relevant technical, economic, and application-specific information that demonstrates the continued need for mercury UV lamp technology, as further stakeholder engagement may occur during the assessment phase.