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European Commission grants RoHS exemption for cadmium and lead in PVC applications

SafeGuardSElectrical & ElectronicsJanuary 30, 2024

SG 20/24

On January 10, 2024, the Official Journal of the European Union published the revised RoHS Directive (EU) 2024/232. This directive adds exemptions for lead and cadmium in recovered rigid PVC for use in electrical and electronic doors and windows to Annex III of Entry 46.

The EU RoHS Directive (2011/65/EU) aims to prevent the risks posed to human health and the environment related to the management of electronic and electrical waste by restricting the use of certain hazardous substances. Due to scientific and technical progress, exemptions have been set up for the use of certain hazardous substances in specific application. The exemptions are listed in Annex III and Annex IV to RoHS Directive. The exemptions in Annex III are suitable for all EEE. Meanwhile, the exemptions in Annex IV are only suitable for medical devices and monitoring and control instruments.

On January 10, 2024, the Official Journal of the European Union published the Directive (EU) 2024/232 to revise the RoHS Directive. This Directive adds exemptions for lead and cadmium in recovered rigid PVC for use in electrical and electronic doors and windows to Annex III of Entry 46 in the RoHS Directive. The details of Entry 46 are summarized in Table 1:

EntryContentScope and validity period
46Cadmium and lead in plastic profiles containing mixtures produced from polyvinyl chloride waste (hereinafter referred to as “recovered rigid PVC”), used for electrical and electronic windows and doors, where the concentration in the recovered rigid PVC material does not exceed 0.1 % cadmium by weight and 1.5 % lead by weight.

From 28 May 2026, rigid PVC recovered from electrical and electronic windows and doors shall only be used for the production of new articles under the categories specified in entry 63, points 18(a) to (d) of Annex XVII to Regulation (EC) No 1907/2006.

Suppliers of PVC articles containing recovered rigid PVC with a concentration of lead equal to or greater than 0.1 % by weight of the PVC material shall ensure, before placing those articles on the market, that they are visibly, legibly and indelibly marked with the statement: “Contains ≥ 0.1 % lead”. Where the marking cannot be provided on the article due to the nature of the article, it shall be on the packaging of the article.

Suppliers of PVC articles containing recovered rigid PVC shall submit to national enforcement authorities upon request documentary evidence to substantiate the claims on the recovered origin of the PVC in those articles. Certificates issued by schemes to provide proof of traceability and recycled content, such as those developed according to EN 15343:2007 or equivalent recognized standards, may be used to substantiate such claims for PVC articles produced in the Union. Claims made on the recovered origin of the PVC in imported articles shall be accompanied by a certificate issued by an independent third-party, that provides equivalent proof of traceability and recycled content
Applies to category 11 and expires on May 28, 2028

Table 1

This entry shall come into force 20 days after its publication, it therefore came into force on January 30, 2024.

With an extensive global network of highly experienced technicians and local state-of-the-art laboratories, SGS has developed a one-stop solution for electrical and electronics manufacturers and suppliers. Discover more on our website and contact us if you would like to find out more about our RoHS services. In the end, it’s only trusted because it’s tested.

© SGS Société Générale de Surveillance SA. This publication or website is a property of SGS Société Générale de Surveillance SA. All contents including website designs, text, and graphics contained herein are owned by or licensed to SGS Société Générale de Surveillance SA. The information provided is for technical and general information purposes only and offers no legal advice. The information is no substitute for professional legal advice to ensure compliance with the applicable laws and regulations. All information is provided in good faith “as is”, and SGS Société Générale de Surveillance SA makes no representation or warranty of any kind, express or implied, and does not warrant that the information will be error-free or meet any particular criteria of performance or quality.

For further information, please contact:

Ethan Zang

Ethan Zhang

Technical Supervisor, EET RSTS

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