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 Exemption 6(a) has been revoked and will phase out within 12 months of the directive’s entry into force. Exemption 6(b) has been revoked as well, with an 18-month phase-out period.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.