UK Launches Consultations on RoHS Exemptions for Lead in Engine Control Units and Mercury in Discharge Lamps

On 10 March 2025, the UK Department for Environment, Food & Rural Affairs (DEFRA) launched two public consultations on proposed exemptions under the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012 (RoHS) in Great Britain (England, Scotland and Wales). Stakeholders are invited to submit comments by 4 May 2025.

About the RoHS Regulation

The RoHS Regulation restricts the use of certain hazardous substances in electrical and electronic equipment (EEE) placed on the market. Originally derived from EU legislation, it aims to reduce the environmental and health risks posed by substances such as lead, mercury, cadmium, and certain flame retardants.

Under the UK RoHS framework, industry can apply for exemptions to allow the use of restricted substances above the specified limits if certain criteria are met. Applications are assessed through a formal evaluation process and, if granted, exemptions apply to the whole - not just the applicant.

Consultation 1: Lead in Engine Control Units

The first consultation concerns a proposed renewal of an exemption allowing the use of lead in solder used in sensors, actuators, and engine control units (ECUs) for combustion engines. The applicant argues that no reliable alternatives are currently available for these components. If granted, the exemption would be valid until 1 January 2027 and would allow the introduction of approximately 0.123 kg of lead per year into the GB market. The consultation is available here.

Consultation 2: Mercury in Discharge Lamps

The second consultation concerns a request for an exemption for the use of mercury in certain discharge lamps designed for special purpose applications. Mercury is currently restricted under RoHS due to its toxicity, but exemptions may apply where no viable alternatives exist, particularly in specialised lighting systems. The consultation can be accessed here.

These consultations are part of DEFRA’s statutory duty to assess requests for exemptions and to ensure that any continued use of restricted substances is technically justified and time-limited. Industry stakeholders, environmental organizations, and other interested parties are encouraged to provide evidence-based feedback. Comments can be submitted until 4 May 2025 via DEFRA’s consultation portal here.