For a project I'm looking for ROHS conform 27xxx eprom types. I found one but all of them have too fast access times not really working with Atari devices. As new devices (cartridges are "devices" according to european regulations) must be ROHS conform it is essential to use compliant one as fee is fairly high. On the other side you risk your product is dumped if crossing borders for ex- or import. A cartridge is "new" if you relabel it or it was produced > 2006 (pre 2006 devices are excluded if not relabeled).

Beside that you must register for WEEE if you produce or relabel it, but this is another story......

is there any replacement for 27xxx eproms which is ROHS conform AND works with higher refresh times (like 200ms)?

If there is none then project is dead anyway.