Status update: RoHS request for prolongation
Under the European RoHS Directive (Restriction of Hazardous Substances – Directive 2011/65/EU), the use of mercury in electrical and electronic equipment is restricted. However, exemptions may be granted when no technically or economically viable alternatives are yet available. Many UV lamps currently used in water, wastewater and air treatment rely on mercury technology, particularly low-pressure and medium-pressure UV lamps.
Background
On 22 August 2025, LightingEurope submitted nine RoHS exemption renewal dossiers to the European Commission. In parallel, the UK Lighting Industry Association (LIA) submitted five related dossiers in the United Kingdom.
Now, the Oeko-Institut together with Fraunhofer IZM on behalf of the European Commission started the approval process. The Oeko-Institut confirmed that stakeholder consultations for these exemptions are planned during 2026.
Current status: public consultation has started
The public consultation for the RoHS exemption evaluations is now open, the deadline is 𝟮𝟰 𝗝𝘂𝗹𝘆 𝟮𝟬𝟮𝟲. The consultation covers:
Public consultation
One of the next major steps is a public stakeholder consultation. During this consultation companies, industry associations, end users, NGO and technology providers will be able to submit evidence, opinions, and technical input directly to the consultants reviewing the exemptions.
Although stakeholder submissions are not legally binding, the consultants are required to consider both supporting and opposing arguments in their final evaluation.
Possible outcomes:
The exemption is denied*
If the European Commission decides not to renew the exemption, European legislation still requires a transition period before the restriction becomes effective.
Industry sources currently expect a legally required transition period of approximately 12 to 18 months. In practice, this would likely mean that conventional mercury-containing UV lamps would not disappear from the market before approximately 2029.
The exemption is renewed
If the exemption is approved, mercury-containing UV lamps can continue to be used under the renewed exemption conditions.
A new renewal request would then likely need to be submitted again before the next expiry date, expected around 2030.
*Importantly if exemption is denied
- The restriction would apply primarily to new equipment placed on the market.
- Spare parts and service continuity are treated differently under RoHS and may remain possible under specific conditions.
LightingEurope has also previously stated that existing exemptions remain valid during the review process until a formal decision is taken by the European Commission.
What this means for the UV industry
The current situation creates uncertainty for manufacturers, OEMs, water treatment companies, and end users relying on conventional UV technology. At the same time, the review process clearly illustrates the broader European policy direction toward the reduction of mercury use and the acceleration of mercury-free alternatives. There is an increased focus on sustainability and circularity.
UV system users and suppliers are therefore advised to:
- Closely monitor the consultation process
- Prepare technical input and application data
- Assess the impact on installed systems and future projects
- Evaluate the readiness of alternative technologies such as UV-LED systems where applicable
What to expect from the UV Alliance
The upcoming public consultation will be an important moment for the UV industry to provide practical input and technical evidence regarding the continued use of mercury-containing UV lamps.
At the UV Alliance, we believe that decisions impacting critical water treatment technologies should be based on facts, practical experience and transparent communication. We therefore encourage all stakeholders to participate in the consultation process and share their expertise. The UV Alliance is preparing a joint industry statement.
Would you like to contribute or be involved? Please contact us at contact@uv-alliance.com or send us a message via LinkedIn.
