Europe Finally Ends the Cadmium QD Exemption
November 21, 2025
Public Service Announcement: If you happen to have a container ship en route to Europe loaded with new QD TVs that have more than 100 ppm of Cadmium in any component, you may want to close this browser tab and get on the sat phone to the captain to turn it around… RoHS Exemption 39(a), which allows >100 ppm of Cadmium in display products, officially and finally ends TODAY.
How we got here
The RoHS cadmium quantum dot exemption has had a long and surprisingly resilient life. The story starts in 2009. As the EU began finalizing what would become the Restriction of Hazardous Substances (RoHS) regulations that would limit the use of a range of hazardous materials in consumer products, they found that in some cases, materials had no practical replacement or their use generated an environmental net-positive result. A series of 39 general exemptions was created to allow the continued use of these materials in limited circumstances.
The last exemption on that list is the one that interests us: Exemption 39. Originally designed for cadmium use in LEDs, not QDs, it nonetheless provided a potential pathway for CdSe QD commercialization:
Cadmium in colour converting II‑VI LEDs (< 10 µg Cd per mm² of light‑emitting area) for use in solid state illumination or display systems.
Early quantum dot products based on CdSe QDs relied on exemption 39. As those products began shipping in late 2013, the EU asked the Oeko Institute to review them. The outcome of that process was exemption 39(a), specifically for QDs in display. Thus began a 12-year regulatory saga.
Exemption 39(a) was first written into Annex III of the RoHS Directive and published in the Official Journal back in 2017, with the idea that it would sunset two years later once alternatives matured.
Timeline of Exemption 39(a) from final reviews to ultimate end, 2019 to 2025.
Instead, it lingered. The European Commission asked the Oeko Institute to review the exemption in 2019 and again in 2022. Each time, the conclusion became clearer: technically viable alternatives existed, and the specific carve-out for cadmium QD films in displays was no longer justified.
The real countdown started when the Commission’s delegated directive was adopted and published in the Official Journal on 21 May 2024. That publication triggered an 18‑month grace period, after which Exemption 39(a) finally expires on 21 November 2025.
What actually changes today
Until now, Exemption 39(a) allowed cadmium selenide based quantum dots in display backlights at relatively high mass per square meter of screen area, even though the base RoHS limit for cadmium in homogeneous materials is 0.01 percent by weight, or 100 ppm.
Once the exemption is gone, that special treatment disappears. New displays placed on the EU market have to respect the same 100 ppm cadmium limit in every homogeneous material, including QD films, adhesives and encapsulants. The only remaining cadmium QD carve out is a new Exemption 39(b) for on‑chip QD color conversion (think, microLED color conversion), which is limited by strict per chip and per device cadmium caps and already has its own expiry date at the end of 2027.
Final language for cadmium QD exemptions 39(a) and 39(b) from the Official Journal of the EU, May 21, 2024.
It is also worth remembering what regulators mean by “placing on the market”. Under EU guidance, that is the first time a product is made available on the EU market. Products that were legally placed on the market while the exemption was still valid can stay in the distribution chain and be sold, but noncompliant products cannot be newly placed on the market after the cutoff (you may still have time to turn that container ship around!).
The 100 ppm problem that remains
If this were a movie, today would be the moment when the cadmium villain is finally defeated and the credits roll. Reality is tidier on paper than in pixels.
The underlying RoHS rule has always allowed up to 100 ppm of cadmium in any homogeneous material, and that does not change with the end of 39(a). Ecodesign rules for electronic displays, which took effect in March 2023, even add a marketing twist: if every homogeneous material in a display stays at or below that 100 ppm threshold, the product must use a “Cadmium-free” logo.
So in strict regulatory terms, Europe has not banned cadmium outright in displays. It has banned high-cadmium formulations and then created a label that calls 0-100 ppm “cadmium free”.
Why the industry is ready anyway
The good news is that the technology is already ahead of the law. Modern quantum dot solutions can hit the RoHS 0 to 100 ppm window and still deliver top-tier color performance, and heavy metal free materials with 0 ppm cadmium and 0 ppm lead are not only in commercial use but lead the market with over 70 percent share. The long review process gave material suppliers and panel makers plenty of time to qualify and ramp these alternatives.
Cadmium’s long goodbye
Today’s milestone closes a very specific chapter: the dedicated exemption that allowed high-loading cadmium QD films in Europe is finally gone. What replaces it is a clearer rule set, a still generous 100 ppm ceiling for cadmium in any homogeneous material, and Ecodesign requirements that reward displays that stay within that 0 to 100 ppm window with a “Cadmium free” logo.
Cadmium-based quantum dots have delivered reference-level color performance for more than a decade, and they will continue to play a role wherever they can meet those RoHS limits. At the same time, the industry has invested heavily in lower cadmium and heavy metal free materials, so panel makers now have a full spectrum of options from CdSe formulations under 100 ppm cadmium to completely cadmium and lead-free solutions.
For display makers, the end of Exemption 39(a) is less a cliff and more a clear signpost. It confirms that the market and the regulators are aligned on reducing cadmium while preserving performance, and it validates the work that has gone into next-generation quantum dot technologies. That is worth celebrating, and Nanosys will keep driving the transition to brighter, more efficient, and ultimately heavy metal free quantum dot displays.
This blog is for informational purposes only and is not legal advice. Please consult your own legal counsel for guidance on RoHS and related regulations.
