Lavanya
Sep 18, 2025
EU RoHS Update: Major Changes to Lead Exemptions
The European Commission has formally adopted the final delegated directives on lead exemptions under the EU RoHS framework, reshaping how manufacturers must plan their compliance strategies over the next several years.
What’s Changing?
The most immediate development is the general extension of expiry dates. Exemptions that were previously due to expire on 31 December 2026 will now remain valid until 30 June 2027, providing companies with six additional months to prepare their renewal applications.
The directives also introduce a significant restructuring of long-standing exemptions. For example, Exemption 7(a), which covers lead in high-melt solder, has now been divided into seven separate sub-exemptions (7(a)-I through 7(a)-VII). Similarly, Exemption 7(c)-I has been split into three parts, with two new sub-exemptions (7(c)-V and 7(c)-VI) created to better reflect the diversity of applications in glass and ceramics. All of these split exemptions will remain valid until 31 December 2027.
Revoked Exemptions and Transition Periods
Not all exemptions have been extended. Exemption 6(a) has been revoked and will phase out within 12 months of the directive’s entry into force. Exemption 6(b) has been revoked as well, with an 18-month phase-out period. Related exemptions 6(b)-I and 6(b)-II will see transition periods ranging from 12 to 18 months for categories 1–7 and 10. This means manufacturers using lead in steel, aluminium, copper alloys, or certain solders will need to act quickly to manage compliance risk.
Renewal Deadlines You Need to Know
Manufacturers that wish to maintain access to exemptions beyond their current end dates must prepare renewal applications well in advance:
By 31 December 2025 for exemptions expiring on 30 June 2027
By 30 June 2026 for exemptions expiring on 31 December 2027
What This Means for Industry
The changes affect a broad range of applications including:
Lead in steel, aluminium, and copper alloys
Lead in high-melt temperature solder
Lead in glass and ceramic components
For companies across electronics, automotive, aerospace, medical devices, and other RoHS-regulated industries, these adjustments mean renewed urgency around compliance planning. The extension provides a little breathing room, but the splitting of exemptions increases complexity. Companies must now carefully assess which sub-exemptions apply to their products and prepare documentation accordingly.
Next Steps
The delegated directives are expected to be published shortly in the Official Journal of the European Union (OJEU). Once published, the clock starts ticking—the 12- or 18-month transition periods for revoked exemptions will officially begin.
Lavanya
Lavanya is an accomplished Product Compliance Engineer with over four years of expertise in global environmental and regulatory frameworks, including REACH, RoHS, Proposition 65, POPs, TSCA, PFAS, CMRT, FMD, and IMDS. A graduate in Chemical Engineering from the KLE Institute, she combines strong technical knowledge with practical compliance management skills across diverse and complex product portfolios.
She has extensive experience in product compliance engineering, ensuring that materials, components, and finished goods consistently meet evolving international regulatory requirements. Her expertise spans BOM analysis, material risk assessments, supplier declaration management, and test report validation to guarantee conformity. Lavanya also plays a key role in design-for-compliance initiatives, guiding engineering teams on regulatory considerations early in the product lifecycle to reduce risks and streamline market access.
Her contributions further extend to compliance documentation, certification readiness, and preparation of customer deliverables, ensuring transparency and accuracy for global stakeholders. She is adept at leveraging compliance tools and databases to efficiently track regulatory changes and implement proactive risk mitigation strategies.
Recognized for her attention to detail, regulatory foresight, and collaborative approach, Lavanya contributes significantly to maintaining product compliance, safeguarding brand integrity, and advancing sustainability goals within dynamic, globally integrated manufacturing environments.