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Peer Group

RoHS and UV Lamps / RoHS EU Regulation / RoHS Exemptions

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Invitation to Collaborate

in Advanced UV for Life

For UV lamps and UV technologies that generate ultraviolet radiation (UV radiation)—colloquially also known as “UV light”indefinite exemptions for the use of mercury (Hg) and other substances in discharge lamps applied under European environmental law for many years. These exemptions were of central importance, particularly for applications such as UV disinfection, industrial UV processes, UV curing, as well as analytical and infrastructural applications.

With the introduction of the RoHS II Directive (Restriction of Hazardous Substances), numerous RoHS exemptions for UV lamps were made temporary and have since been subject to regular review as part of the EU RoHS exemption process. For manufacturers, integrators, and users of UV sources, including low-pressure, medium-pressure, and high-pressure UV lamps as well as alternative UV technologies such as UV LED systems, this results in new regulatory requirements, but also technological and strategic opportunities.

Against this background, a working group on RoHS, mercury regulation, and future technologies in the UV market was established. The goal is to support members in implementing RoHS compliance, evaluating substitution options, and in strategic planning within the regulatory environment of EU environmental legislation.

Participation in the working group is open to all members. These include manufacturers of UV lamps and UV systems, system integrators, plant engineers, operators of UV disinfection and industrial plants, as well as other stakeholders along the UV technology value chain.

Goals

Addressing Challenges

To support members in addressing the challenges and opportunities related to the Hg-/RoHS-compliant future of UV lamps.

The topics will be determined by the participants themselves. The following potential topics can serve as a guide:

  • Legislation and Compliance: Current developments, impact of RoHS on Hg-containing and Hg-free UV lamps, identification of necessary actions (possibly application-specific), potentially other legal compliance issues (REACH, ErP, WEEE), dealing with a worst-case scenario (expiration of exemptions).
  • Influencing and Exemption Applications for RoHS: Representing members’ interests, support with exemption applications, best practice recommendations, chances of success.
  • Evaluation of Technological Alternatives: Hg-free, Hg-reduced, excimer and UV-LED sources, market readiness, roadmap, requirements by application fields (e.g., water disinfection, UV curing, UVA, UVB, UVC).
  • Requirements and Challenges for Excimer and UV-LEDs: Consequences for manufacturers and users of alternative technologies in case of early termination of RoHS exemptions, market readiness, market expectations, skilled workforce, supply chains, availability, manufacturer capacities, …
  • Legislation and Compliance of Alternatives such as Excimer and UV-LEDs: RoHS, REACH, ErP, WEEE, other requirements (also applicable to non-Hg-containing products, other possible toxic components?).
  • Environmental Management, Disposal, Replacements: Legal requirements for disposal or replacement of Hg lamps – with or without end of exemptions, responsibility of manufacturers versus integrators versus users.
  • Customs and Supply Chains: Requirements for customs/import/export documents to distinguish between prohibited and allowed Hg lamps, impact of general Hg bans on availability, price, and procurement of UV lamps (all technologies).
  • Strategy Development: Support in developing strategies for continued use or transition to RoHS-compliant sources, adaptation and changes of business models.
  • Networking and Collaboration: Connecting members with experts, decision-makers, and multipliers.
  • Public Image and Positioning: Communication in the tension field between the positive role of Hg-UV (e.g., drinking and wastewater treatment) and environmental protection (renunciation of Hg), avoidance of “greenwashing”, positioning of Advanced UV for Life as a reliable, neutral source on the topic of UV and Hg (Hg-free), common public stance of all members on the topic.

Expression of Interest

I express my interest in active participation. Interested parties will receive an invitation with further information at a later date.

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Please forward to interested colleagues!

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