Prolongation mercury-containing UV lamps
The European UV and lighting industry is currently awaiting the next phase in the review process of several RoHS exemption renewal requests concerning mercury-containing lamps. These exemptions are highly relevant for UV-C systems used in water treatment, industrial processes, and other specialized applications. In this article we give you an update on the current status and the public consultation process.
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.
Current status: public consultation contributions publised
The public consultation for the RoHS exemption evaluations ended on August 1st 2026. The outcome of the consultation was recently published on the Oeko website:
Public consultation evaluation process
During the public consultation, companies, industry associations, end users, NGO and technology providers submitted 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 to expect from the UV Alliance
The public consultation was an important moment for the UV industry to provide practical input and technical evidence regarding the continued use of mercury-containing UV lamps. The large number of companies and organisations that participated in the RoHS public consultation demonstrates how significant the interests around UV lamp technology are — and how important it is to safeguard its continuity.
The UV Alliance, representing European UV companies, has also submitted a joint contribution to the consultation, providing practical industry input and technical evidence.
- UV Alliance’s response regarding derogation 4(a)-I Low-pressure UV lamps
- UV Alliance´s response regarding derogation 4(f)-IV Medium-puressure and high output UV lamps
We will continue to actively monitor the RoHS exemption evaluation process and keep the UV industry informed about further developments.
Would you like to contribute or be involved? Please contact us at contact@uv-alliance.com or send us a message via LinkedIn.
