On 12 December 2025, the Official Journal of the European Union published Directive (EU) 2025/2456, amending Directive 2011/65/EU (RoHS Directive) on the restriction of hazardous substances in electrical and electronic equipment. The amendment transfers certain scientific and technical responsibilities under RoHS to the European Chemicals Agency (ECHA).
Key Amendments
1. Updates to Substance Restrictions (Annex II)
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ECHA is formally assigned responsibility for preparing dossiers related to substance restrictions. The proposals may be submitted either by Member States or by ECHA at the request of the European Commission.
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The list of restricted substances under Annex II will be reviewed on a regular basis, at least once every four years.
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Effective date: 13 August 2027
2. Revisions to RoHS Exemption Procedures (Annex V)
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Responsibility for submitting exemption applications shifts from the European Commission to ECHA.
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A new 45-day completeness check is introduced. If an application is deemed incomplete, ECHA may allow an additional 60 days for supplementary information, with a possible 5-working-day extension for decision-making.
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Once an application is confirmed as complete, ECHA must obtain:
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Draft opinions from RAC and SEAC within 9 months, and
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Final opinions within 12 months will then be forwarded to the European Commission.
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The European Commission must decide on the exemption within 9 months of receiving ECHA’s final opinions.
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Applications for exemption renewals must be submitted at least 18 months prior to expiry. Existing exemptions will remain valid until a final decision is issued.
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Effective date: 27 August 2027
Overall, the revision supports the “one substance, one assessment” principle, aims to harmonize chemical risk assessment across EU legislation, enhance transparency and efficiency, reduce administrative burden, and improve consistency and coordination among EU regulatory frameworks.
