European Economic Area
European Economic AreaRestriction of Hazardous Substances (RoHS)
EU Crackdown On Delayed Directive Transposition
The EU Commission has launched legal proceedings against 27 Member States for failing to transpose key directives affecting manufacturing, electronics, and financial sectors. Businesses must act swiftly to meet compliance deadlines, particularly for RoHS, VAT, and environmental reporting regulations, to avoid potential fines and trade restrictions.
Published in February 2025. Dates, deadlines and stages may have changed since.
Dr Steven Brennan
2 min readAI-drafted, expert reviewed
The European Commission has launched infringement proceedings against 27 Member States for failing to fully transpose 11 EU directives, impacting industries from chemicals to electronics and finance. Formal notices were issued on 31 January 2025, giving Member States two months to comply or face further legal action.
Manufacturers Face Compliance Uncertainty
The affected directives include air pollutant emissions, hazardous substances in electronics (RoHS), financial regulations (Daisy Chains II), VAT schemes, and corporate gender balance requirements. Businesses across the manufacturing supply chain, chemicals, electronics, and financial sectors now face uncertainty regarding compliance obligations.
Key Directives Under Scrutiny
Hazardous Substances In Electronics: RoHS Directive
Cyprus failed to transpose Commission Delegated Directive (EU) 2024/1416, amending the Restriction of Hazardous Substances (RoHS) Directive 2011/65/EU. This directive narrows exemptions for cadmium in LED applications, requiring businesses to seek alternative materials and update compliance strategies.
Air Pollutant Emission Projections
Bulgaria, Denmark, Germany, Cyprus, Hungary, The Netherlands, Portugal, Slovakia, and Finland missed the 31 December 2024 deadline to transpose Directive (EU) 2024/299, aligning EU reporting with UN pollution standards. Failure to comply could lead to reporting penalties.
Financial Sector: Daisy Chains II Directive
Seventeen Member States, including France, Germany, and Italy, failed to implement the Daisy Chains II Directive (EU) 2024/1174, which restructures minimum capital requirements for banks and investment firms. This regulatory gap could create market uncertainty for financial institutions and service providers.
Compliance Deadlines And Business Implications
5 December 2024 – Transposition deadline for the Ferry Safety Directive.9 December 2024 – Implementation of the EU Emergency Travel Document.31 December 2024 – Key deadlines for RoHS, VAT, and air pollution directives.28 December 2024 – Corporate gender balance directive compliance date.
Manufacturers, importers, and service providers should assess supply chain risks, ensure product compliance, and prepare for potential enforcement actions. The Commission may escalate non-compliance cases to the Court of Justice of the EU, leading to financial penalties and trade restrictions.
Official source
ec.europa.euQuestions about this change
What are the risks for businesses if Member States delay EU directive transposition?
Delays in transposition create regulatory uncertainty, affecting supply chains, compliance costs, and investment decisions. Businesses may face unexpected legal requirements, penalties, or product bans, particularly in regulated industries like chemicals, finance, and electronics.
How can manufacturers prepare for the new RoHS Directive changes?
Manufacturers should review supply chains, phase out restricted substances like cadmium in LED applications, and update compliance documentation. Engaging with regulatory experts and industry groups will help navigate the new exemption limitations under Directive (EU) 2024/1416.
Dr Steven Brennan
CEO and co-founder of Foresight, and a co-opted member of ECHA's Committee for Socio-economic Analysis. He holds a PhD in chemical engineering.
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