The UK Department for Environment, Food & Rural Affairs (Defra) has opened four public consultations on exemptions under the Restriction of Hazardous Substances (RoHS) regulations. These exemptions relate to the continued use of lead, mercury, and cadmium in essential industrial applications, including internal combustion engines, lighting, and Raman spectroscopy.
Businesses and stakeholders across the manufacturing, engineering, and industrial sectors have until 4 May 2025 to submit their views.
1. Lead in Bearings and Bushes of Diesel and Gaseous Fuel-Powered Engines
Impact on the Heavy Machinery and Industrial Sectors
The first consultation concerns the renewal of an RoHS exemption for lead in bearings and bushes used in non-road diesel and gaseous fuel-powered engines. These components are critical for agriculture, construction, and mining equipment.
The European Association of Internal Combustion Engine Manufacturers (EUROMOT) has requested a five-year extension, arguing that no suitable lead-free alternatives can yet meet performance and durability requirements.
Key concerns:
- The continued use of 128kg of lead annually in the UK market.
- Lack of verified alternatives for extreme working conditions.
- Potential operational and cost impacts if the exemption is not renewed.
Manufacturers, suppliers, and end-users are encouraged to provide input on available substitutes, economic implications, and potential risks to industry operations.
2. Lead Solder in Engine Control Units (ECUs) of Combustion Engines
Ensuring Reliability in Harsh Environments
The second consultation covers the use of lead solder in sensors, actuators, and ECUs for combustion engines. This exemption applies to fixed-position industrial equipment such as generator sets and fluid pumps.
The renewal request extends the exemption to January 2027, allowing time for the development and testing of lead-free solder alternatives.
Key considerations:
- The introduction of 0.123kg of lead annually into the market.
- Harsh environmental conditions (e.g. extreme temperatures, high vibrations, and corrosion) require robust soldering solutions.
- Lead-free alternatives such as tin-silver-copper (SAC) and Innolot alloys are in development but not yet fully validated.
Stakeholders are invited to submit evidence on the progress of lead-free alternatives and the feasibility of transitioning to new materials.
3. Mercury in Discharge Lamps for Special Purposes
Balancing Environmental Concerns with Industrial Needs
The third consultation evaluates the renewal of an exemption allowing mercury in discharge lamps used for specialised industrial and entertainment applications, including stage lighting and flight simulators.
The Lighting Industry Association (LIA) has applied for a five-year extension, citing the lack of viable alternatives to match mercury’s low boiling point and broad spectrum light emission.
Issues at stake:
- Less than 1kg of mercury per year would be introduced under this exemption.
- LED and laser lighting are being tested as alternatives but do not yet meet the required performance criteria.
- The potential phase-out could lead to premature obsolescence of existing equipment and additional waste generation.
The government is seeking feedback from manufacturers, end-users, and environmental experts on the feasibility of alternative mercury-free lighting solutions.
4. Helium Cadmium Lasers in Raman Spectroscopy
Ensuring Precision in Scientific and Industrial Applications
The fourth consultation focuses on the use of cadmium in helium-cadmium (HeCd) lasers, which are critical for Raman spectroscopy. This technique is used for chemical analysis, material identification, and molecular structure studies in industries including pharmaceuticals, semiconductors, and advanced materials.
The Japan Business Council in Europe (JBCE) has requested a seven-year extension, stating that no alternative laser system provides the required 325nm wavelength with the same stability.
Key points of discussion:
- 200g of cadmium annually would be used under this exemption.
- The absence of drop-in replacements for existing Raman spectroscopy applications.
- The development of alternative technologies, such as diode-pumped solid-state (DPSS) lasers, is still ongoing.
The government is gathering insights from scientific researchers, equipment manufacturers, and industrial users to assess the feasibility of cadmium-free Raman lasers.
Next Steps: Have Your Say
The UK government urges manufacturers, industry associations, researchers, and stakeholders to participate in these consultations.
How to Respond
- Submit feedback via the Defra Citizen Space platform before 4 May 2025.
- Provide data on alternative materials, economic impacts, and environmental considerations.
- Engage in follow-up discussions with Defra for technical clarification and industry impact assessments.
