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The current RoHS Directive vs. UV lamps and UV LEDs - regulation and development

The current European Union regulations on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS Directive) have introduced significant changes regarding mercury-containing lamps with UV emission. The EU has removed many existing exemptions for the use of mercury in lamps and limited others, as mercury-free alternatives are now widely used and available.

Directive 2011/65/EU (RoHS 2) replaced its predecessor Directive 2002/95/EC (RoHS 1) on January 3, 2013. The transitional period for exemptions for many products ended on July 21, 2021, after which stricter requirements, often referred to as RoHS 3, apply.

As RoHS 3, exemptions are limited in time. The adaptation of the exemptions in Annex III is linked to scientific and technical progress.

For UV lamps, a time-limited exemption for mercury in discharge lamps was created in accordance with Annex III, categories 4a to 4f. The current deadline for the following lamps expires on February 24, 2027:

  • Mercury in fluorescent lamps emitting mainly light in the ultraviolet spectrum and not exceeding 15 mg mercury (per lamp)
  • Mercury in low pressure discharge lamps without fluorescent coating "UV-C", where the application requires that the main range of spectral lamp output is in the ultraviolet spectrum and which do not exceed 15 mg mercury (per lamp)
  • Mercury in metal halide lamps (MH)
  • Mercury in high-pressure mercury (vapor) lamps used in projectors requiring an output ≥ 2000 ANSI lumens
  • Mercury in lamps emitting light in the ultraviolet spectrum (medium pressure lamps, amalgam lamps)
  • Mercury in low pressure discharge lamps without fluorescent coating where the application requires the main range of spectral lamp output to be in the ultraviolet spectrum: Up to 15 mg of mercury may be used per lamp

The RoHS Directive prohibits the "placing on the market" of new mercury-containing UV lamps once the exemption has expired. However, the use of existing lamps and the sale of remaining stocks remain permitted.

According to Article 4, point (4) f) of the ROHS, the supply of spare parts is also ensured for systems that were installed before 24.02.2027.

The exemptions only apply until the elimination or substitution of the banned substances is scientifically or technically practicable. The reliability of substitute products must be guaranteed and, in addition to other aspects, the substitution must have advantages for the environment, health and safety of consumers. 

In this context, we see the current development of UV LEDs and UV lamps as follows:

The regulations aim to reduce the use of toxic mercury in lamps and switch to mercury-free alternatives such as LED technology in the long term.

There are very good and superior substitutes for UVA lamps in the form of UVA LEDs (emission at 365 nm and longer wavelengths). We therefore recommend the use of UVA LEDs for new developments and the introduction of new processes.

However, for special applications, applications with high radiation fluxes and applications that require UV-B or UV-C radiation, this poses a challenge, as no equivalent mercury-free alternatives are yet available. Even though the development of new UV-B and UV-C LEDs is making great progress, the development of UV-B and UV-C LED technology has not yet reached the point where the advantages outweigh the disadvantages.

In 2015 and 2020, well-founded applications for extensions of the exemptions in Annex III were submitted to the EU. The decision was made with the involvement and consultation of market participants. The next extensions should therefore be initiated as early as 2025. See this.

Historical development of mercury regulation

The regulation of mercury has a long and complex history that is closely linked to environmental and health disasters. The Minamata disaster in Japan, which began in the 1950s, is particularly noteworthy. The discharge of mercury-containing wastewater into Minamata Bay caused massive environmental damage and serious health effects on the local population. This catastrophe drew global attention to the dangers of mercury and led to increased efforts to regulate the pollutant.

The Minamata Convention aims to protect human health and the environment globally from mercury emissions. It regulates the entire life cycle of mercury, from mining to disposal.

In the European Union (EU), numerous legal measures have been taken in recent decades to minimize the use of mercury. An important milestone was the introduction of the RoHS Directive (Restriction of Hazardous Substances) in 2003, which aimed to restrict the use of certain hazardous substances such as lead, mercury, cadmium, hexavalent chromium and polybrominated biphenyls in electrical and electronic equipment.

The current RoHS Directive, which has been in force since 2019, has further tightened the requirements and further reduced the permissible limits for mercury and other hazardous substances. With the publication of ROHS II (2011/65/EU), the exemption for UV lamps was limited in time.

Since 2022, the European Commission has published several legal acts that further restrict the use of mercury and chemicals, for example. One example of this is the REACH Regulation.

Legal requirements in connection with mercury in UV lamps

The EU's RoHS 3 Directive sets strict requirements for the use of mercury in UV lamps. UV lamps are used in a variety of applications, including water and air disinfection, in the printing industry and in medical devices. Despite their useful properties, the mercury contained in these lamps poses an environmental and health risk.

According to the RoHS 3 directive, UV lamps may only contain a very small amount of mercury. The permissible limit for mercury in UV lamps is 5 mg per lamp. Companies that manufacture or sell UV lamps must ensure that their products do not exceed this limit. In addition, they must prove compliance with the directive through appropriate labeling and documentation.

Phasing out mercury in lamps: technical alternatives and challenges

The phasing out of mercury in lamps poses both technical and economic challenges. Mercury is an essential component in many UV lamps, as it is a very effective and stable source when irradiated with UV light. The development of mercury-free alternatives therefore requires considerable research and development efforts.

UV LEDs are a promising alternative to mercury-containing UV lamps. These lamps use semiconductor technology instead of mercury and offer numerous advantages, including a longer lifetime, lower energy consumption and immediate operational readiness without warm-up time. Despite these advantages, UV LEDs are not yet able to fully match the performance of mercury vapor lamps in certain applications (e.g. in UV-C or UV-B or at high radiation fluxes). Further technological progress is required, particularly in high-performance applications and in water disinfection, to enable complete substitution.

The market for UV lamps has changed considerably in recent years. While mercury-containing UV lamps are still available, the demand for environmentally friendly alternatives is steadily increasing.

In addition to UV LEDs, there are other technologies that can be considered as alternatives to mercury-containing UV lamps. For example, excimer lamps offer a mercury-free option that is highly efficient and effective in certain applications. These lamps generate UV light through the excitation of noble gases and therefore offer an environmentally friendly solution for specific applications.

Overall, it is clear that the regulation of mercury in UV lamps presents both a challenge and an opportunity for innovation. Companies need to proactively address the legal requirements while investing in the development and implementation of environmentally friendly alternatives. 

Whether UV lamps will be banned is questionable. Should a staggered ban be introduced, we therefore assume an initial ban on low-wattage UVA lamps, while high-wattage UV lamps and lamps with UVB and UVC emissions cannot and do not yet have to be replaced.