If you follow compliance news closely, you probably felt the ripple effect when the European Commission quietly dropped the latest EU RoHS update into the Official Journal. It arrived on November 21, 2025, without much noise, but the impact is anything but subtle. Lead exemptions—especially the big ones everyone relies on (6, 7a, 7c)—just got reshaped, split, redefined, tightened, and assigned new expiry clocks.

Most teams expected an update, sure, but not this level of restructuring. And definitely not this level of technical specificity. If you work with components that rely heavily on legacy exemptions, this shouldn’t just be a footnote in your compliance calendar. It’s a significant shift that needs you to start real adjustments.

Let’s break down what happened, what’s new, and what this means for your operations in real-world terms—because compliance deadlines are never abstract when you’re the one responsible for preventing a product-launch fire drill.

A Quick Snapshot of the Regulation

Name of Regulation: EU RoHS

Framework Affected: EU RoHS Directive

Regions Impacted: All areas that sell into, export to, or integrate supply chains with the EU. If your product moves through Europe at any point, these updates are yours to track—no exceptions.

Entry Into Force: December 2025 (20 days after publication)

What Exactly Happened on 21 November 2025?

On this date, the European Commission formally published delegated directives for lead exemptions 6, 7a, and 7c. These directives aren’t tiny revisions—they reshape how exemptions are structured, defined, and ultimately phased out.

The updates landed under three core documents:

• Exemption 6: Delegated Directive – EU – 2025/2364

• Exemption 7a: Delegated Directive – EU – 2025/1802

• Exemption 7c: Delegated Directive – EU – 2025/2363

If your engineering teams reference 6(a), 6(b), 6(c), or the looser versions of 7(a)/7(c), they now need to relearn the structure, because the Commission has re-indexed and reshuffled these EU RoHS lead exemptions.

What’s New in the Update?

The new EU RoHS lead exemptions fall into three buckets:

a. More Precise Sub-entries

Exemptions now cascade into narrower sub-entries—such as 6(a)-I, 6(a)-II, 6(b)-III—reflecting more nuanced technical use cases.

This removes the ambiguity that used to cause teams to guess whether their application fit into one bucket or another. But on the flip side, this also means your documentation, declarations, and ERP reference codes must be updated. And that too pretty quickly.

b. Stronger Technical Conditions

The wording now includes clearer thresholds, application types, and stricter boundaries for allowable lead content. The Commission made it harder for companies to slip legacy components under broad exemptions.

This is where planning beats rushed firefighting—because the window for transition is not generous.

c. Harmonized Expiry: 30 June 2027

Most renewed exemptions now align to a single sunset date: 30 June 2027.

This alignment simplifies long-range planning but shortens the runway for some industries.

Key Expiry Dates You Need to Lock In Now

Here’s the practical, no-fluff rundown. If you’re responsible for bill of materials (BOM) mapping, this is your checklist:

Expires 31 December 2027

• 7(a)-I

• 7(a)-II

• 7(a)-III

• 7(a)-IV

• 7(a)-V

• 7(a)-VI

• 7(a)-VII

• 7(c)-II

• 7(c)-V

• 7(c)-VI

Expires 30 June 2027

• 6(a)-I

• 6(a)-II

• 6(b)-I

• 6(b)-II (Categories 9 & 11)

• 6(b)-III

• 6(c)

• 7(a)

• 7(c)-I

Revoked with Transition Periods

• 6(a), 6(b)-I, 6(b)-II (Categories 1–7 & 10) - Valid until 11 December 2026

• 6(b), 6(b)-II (Categories 1–7 & 10) - Valid until 11 June 2027

Renewal Deadlines

• Entries expiring 30 June 2027 → Renewal request due 31 December 2025

• Entries expiring 31 December 2027 → Renewal request due 30 June 2026

These dates should already be penciled in your product calendar software. If not, today is your day.

Why This Update Matters More Than You Think

Here’s the reality most companies don’t want to say out loud:

You're not just managing a regulation update—you're managing engineering dependencies that have often existed for years, sometimes decades. When an exemption shifts, the ripple affects BOMs, supplier declarations, procurement contracts, product lifecycle plans, and tester specs.

This update matters because:

• It forces manufacturers to re-map components across all active product lines.

• It requires suppliers to refresh declarations with the new exemption codes, not the legacy ones.

• It pushes companies to rethink long-term component availability, especially for parts approaching sunset.

• It realigns engineering teams toward substitution projects they may have delayed.

The most significant risk is documentation mismatch—when a supplier uses an outdated 6(a) code even though the Commission has replaced it with 6(a)-I or 6(a)-II. Auditors catch this faster than you think when reviewing EU RoHS lead exemptions.

And this is precisely where teams are leaning heavily on tools like Certivo for RoHS compliance automation, and even AI-driven compliance automation, to avoid human misinterpretation errors. More on that shortly.

The Role of Technology: Why Automation Is Becoming a Lifeline

Compliance used to be a spreadsheet exercise. Then it became a supplier-chasing exercise. Now it’s a full-blown data-management challenge—primarily when exemptions are split into sub-entries with tighter clauses and expiry clocks.

The 2025 changes make one point painfully clear: Manual tracking isn’t just slow—it’s risky.

Across the industry, two shifts are visible-

1. Automated tools are replacing manual updates

Systems built for RoHS compliance automation now flag:

• expiring exemptions

• mismatched codes

• incorrect lead thresholds

• category-specific timelines

• supplier documents referencing revoked entries

Teams save weeks of back-and-forth by letting systems automatically validate declarations.

2. AI is finally proving useful in regulatory workflows

This isn’t hype. Companies are now deploying:

• AI for regulatory compliance to parse delegated directives

• AI-driven compliance automation to easily categorize components under the correct sub-entries

• Risk alerts that flag components tied to high-sunset-risk exemptions

• Dashboards that show which SKUs collapse if an exemption expires without renewal

You also see compliance teams relying on Automated RoHS exemption tracking to keep supplier declarations up to date without email-chasing every quarter.

Is AI replacing human judgment? Not even close. But it’s finally replacing repetitive work that drains your time and increases your risk of missing a deadline.

How to React to the 2025 Update Without a Panic Spiral

Here’s a simple, honest roadmap:

Step 1: Rebuild Your Exemption Mapping

Every component that previously used 6(a), 6(b), 6(c), 7(a), or 7(c) must be reassigned to the updated sub-entry.

If you use PLM, ERP, or supplier portals, update the exemption list immediately.

Step 2: Notify and Align Your Suppliers

Make sure every supplier switches to the new codes for the updated EU RoHS lead exemptions. One outdated code creates a cascade of compliance errors downstream.

Step 3: Update Internal Documentation

This includes: Technical files, Due diligence records, Conformity documentation, Supplier declarations, Product-level RoHS dossiers.

Step 4: Start Substitution Projects Now

Many companies underestimate lead-free redesign timelines. If your product line depends on sub-entries expiring in 2027, waiting until 2026 is a guaranteed scramble.

Step 5: Integrate AI if you haven’t already

Tools that combine data ingestion, supplier tracking, and revision alerts—especially those driven by AI—provide the leverage your team likely needs.

This is where platforms offering Automated RoHS exemption tracking and AI-driven compliance automation become lifesavers, not luxuries.

The Bigger Picture: What This Update Signals for the Future

The European Commission’s restructuring didn’t happen in isolation. It signals a long-term regulatory direction:

• Fewer broad exemptions

• More narrow, technically specific sub-entries

• Shorter sunset dates

• More pressure to adopt lead-free alternatives

• Higher documentation granularity

In short:

RoHS is tightening, not stabilizing.

Quick Access to the Official Directives

Here are the original publications (no URLs, just titles for referencing):

• Exemption 6: Delegated Directive – EU – 2025/2364

• Exemption 7a: Delegated Directive – EU – 2025/1802

• Exemption 7c: Delegated Directive – EU – 2025/2363

Conclusion

The latest EU RoHS update is not just a refresh—it’s a structural rewrite of the exemptions manufacturers rely on. With tighter definitions, harmonized expiry dates, and new sub-entries, your compliance workload just expanded.

The deadline clock is ticking. The companies that stay ready will glide through the next audit cycle. The ones that wait? They’ll be scrambling when the 2027 sunsets hit.

If your product line touches the EU, now is the moment to align, update, and prepare—before the window closes. **Book a demo with us** and see the magic of AI for regulatory compliance unfold.