Sun tanning lamps: exemption for lead as the activator

Closes 10 May 2024

Opened 15 Mar 2024


The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012 (the RoHS regulations) restricts the use of 10 hazardous substances in electrical and electronic equipment (EEE), with a view to contributing to the protection of human health and the environment, including the sound recovery and disposal of waste.

Industry can apply for exemptions to allow the supply of products using one or more of the restricted substances above the threshold limits set down in the RoHS regulations where specified criteria are met. Applications for exemptions are made to the Secretary of State under regulation 6 of the Hazardous Substances and Packaging (Legislative Functions and Amendment) (EU Exit) Regulations 2020 (the 2020 regulations). Any exemption that is granted can be used across industry, not just by the business that applied for the exemption. Exemptions are granted where it is determined that the necessary criteria have been met following a detailed evaluation conducted in accordance with regulation 5 of the 2020 regulations.

Following the UK’s withdrawal from the EU, the function of granting, renewing and revoking exemptions were, in relation to Great Britain, transferred to the Secretary of State by the 2020 regulations, using powers in section 8 of the European Union (Withdrawal) Act 2018 (the Withdrawal Act).

Part of the evaluation process is an 8-week consultation to collect contributions from stakeholders.

A request for renewal for an exemption was submitted for lead as an activator in the fluorescent powder of discharge lamps used in sun tanning lamps. These lamps are used for cosmetic sun tanning. The tanning lamps are intended to replicate sunlight exposure for the human body and can be for home use or in commercial sun tanning salons. Lead is the primary activator for the fluorescence of the barium silicate phosphor coating which enables the transformation of radiation to specific wavelengths within the UV spectrum.

The requested duration of the exemption is for 5 years and according to the application it would be expected to lead to the introduction of 26.95 kg of lead to the GB market annually. The applicant states that no suitable substitutes have been verified to meet the technical performance required.

 The exemption covers applications under category 11 (all other electronic and electrical equipment not covered under the other categories) of electrical and electronic equipment (EEE), as covered in the 2012 RoHS regulations.

Give us your views


  • Environmental professional services
  • Retail Industry
  • Manufacturing Industry


  • Waste and recycling
  • Chemicals and pesticides
  • Consultations