The EU has restructured its RoHS Annex III lead exemptions, and seven Member States are now under formal infringement pressure for not transposing the changes on time. On 16 July 2026, the European Commission sent letters of formal notice to Spain, Cyprus, Latvia, Hungary, Malta, Portugal, and Slovakia for failing to bring three delegated directives into national law by the 30 June 2026 deadline. For manufacturers, the substantive change is not the infringement itself. It is that the broad lead exemptions many products have relied on for years have been split into narrower, application-specific sub-entries with staggered expiry dates running through 2027.

If your bill of materials contains leaded solders, leaded brass, leaded aluminium, or leaded glass and ceramics, your existing exemption justification may no longer map cleanly to the revised Annex III. This article explains what changed, which entries expire when, and how to re-map each exemption claim before the earliest deadlines arrive.

Before you evaluate your exposure, you can request a compliance review to see how your leaded components map to the revised exemptions.

Key Takeaways

📌 The EU renewed and restructured RoHS Annex III lead exemptions through three delegated directives, (EU) 2025/1802, 2025/2363, and 2025/2364, adopted 8 September 2025 and published 21 November 2025.

⏳ National transposition was due 30 June 2026, with provisions applying from 1 July 2026. On 16 July 2026 the Commission opened infringement procedures against seven Member States.

⚠️ The scope is not uniform. All seven states were cited for the solder and glass/ceramic directives, but only five (Spain, Latvia, Hungary, Malta, Slovakia) were cited for the steel, aluminium, and copper directive. Cyprus and Portugal were not.

📌 Broad parent entries 7(a), 6(a), and 6(b) were segmented into application-specific sub-entries. An exemption claimed generically now needs to be matched to a named sub-entry, and some applications may have no remaining cover.

🏭 Electronics, semiconductors, capacitors, lighting, audio, machined metal parts, and aluminium and steel components are all affected across RoHS categories 1 to 11.

📊 The infringement creates no new obligation on manufacturers. The revised entries apply EU-wide from 1 July 2026 regardless. Technical files should cite the EU-level directives as the compliance baseline.

🤖 Re-mapping exemptions from parent entries to specific sub-entries at BOM level is the core work, and it is where AI-driven regulatory intelligence and automated supplier data collection reduce manual effort and audit risk.

What Changed in the RoHS Annex III Lead Exemptions

RoHS Directive 2011/65/EU restricts lead to a maximum of 0.1% by weight in homogeneous materials, subject to time-limited exemptions listed in Annex III. Historically, several of those exemptions were broad. Entry 7(a), covering lead in high melting temperature solders, applied across most equipment categories without naming specific applications. Entries 6(a) and 6(b) covered lead in steel and aluminium in similarly general terms.

The three 2025 delegated directives change that structure. Rather than simply extending the old entries, the Commission segmented the broad exemptions into narrower sub-entries, each tied to a defined technical application and given its own expiry date. The Commission's stated rationale for splitting 7(a) is that the exemption was widely used and sometimes without any technical need for it. Segmentation forces an application-specific justification at the next renewal.

This is the practical shift for compliance teams. Under the old wording, an operator could rely on a parent entry generically. Under the revised RoHS Annex III lead exemptions, each claim must be matched to a specific sub-entry, and some applications may not fall under any of them. For background on how earlier lead exemption changes played out, see Certivo's analysis of what the latest lead exemption changes mean for manufacturers and the follow-up on lead exemptions extended, split, and revoked.

RoHS Annex III lead exemptions split into application-specific sub-entries diagram

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The Three Delegated Directives Explained

The restructuring is spread across three instruments, each covering a different material family. Treating them as a single change is a mistake, because their national transposition status now differs.

All three were adopted on 8 September 2025, published in the Official Journal on 21 November 2025, and entered into force on 11 December 2025. The Commission has confirmed that renewing the exemptions does not weaken environmental or health protection. For the primary text, see Commission Delegated Directive (EU) 2025/1802, Directive (EU) 2025/2363, and Directive (EU) 2025/2364. Certivo's RoHS framework page tracks how these entries connect to the wider restricted substances regime.

What the July 2026 Infringement Action Means

Member States were required to adopt and publish national implementing measures by 30 June 2026 and apply them from 1 July 2026. On 16 July 2026, in its monthly non-transposition package, the Commission opened first-stage infringement procedures by sending letters of formal notice to states that had not communicated transposition measures.

The scope differs by directive, and this detail matters for market planning:

• Spain, Cyprus, Latvia, Hungary, Malta, Portugal, Slovakia were cited for the solder directive (2025/1802) and the glass and ceramic directive (2025/2363).

• Spain, Latvia, Hungary, Malta, Slovakia were cited for the steel, aluminium, and copper directive (2025/2364). Cyprus and Portugal were not cited for this directive.

Each Member State has two months to respond and complete transposition. If the response is unsatisfactory, the Commission may issue a reasoned opinion, and for failure to notify transposition measures it may ultimately refer the case to the Court of Justice with a request for financial sanctions. The two-month window closes around mid-September 2026, so a reasoned opinion after that date would signal a state has not remedied the gap.

Do not treat all three directives as having the same national gap. The steel, aluminium, and copper exposure covers only five states, and confirming that distinction with local counsel protects you from misjudging your position in Cyprus and Portugal.

RoHS Annex III lead exemptions transposition gap across seven EU Member States

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Does This Create a New Obligation for Manufacturers?

No. This is a legal-certainty and market-access issue, not a product-compliance change. Infringement procedures run between the Commission and the Member State. No new obligation falls on manufacturers, importers, or distributors.

What matters is that the substantive obligation is unchanged and EU-wide. The revised Annex III entries apply from 1 July 2026 as a matter of EU law. In a state that has not yet transposed, national RoHS measures still contain the pre-amendment Annex III text, so the new sub-entries do not formally exist in that national law yet.

After the transposition deadline passes, a sufficiently precise directive provision can be relied on by an operator against a Member State authority, which is vertical direct effect. A Member State cannot rely on its own untransposed directive to worsen an operator's position, and directives have no horizontal direct effect between private parties. In practice, the new exemption text works as a shield, not a sword. The Article 5(5) mechanism that keeps an exemption valid while a renewal application is pending has now been exhausted for these entries, because the Commission has decided. Your technical documentation should cite the EU-level directives as the baseline, then name the specific sub-entry and its expiry date. Consolidating that evidence in a centralized compliance data backbone keeps declarations consistent across every jurisdiction you serve.

Revised Exemptions and Expiry Dates You Must Track

The single most important operational task is re-mapping each exemption claim from the old parent entry to the specific new sub-entry, then diarising the earliest applicable expiry rather than the latest.

The verified expiry dates are as follows:

⚠️ The aluminium series (6(b)-I, 6(b)-II, 6(b)-III) carries category-dependent caps and expiry dates, and secondary interpretations differ on the exact lead cap and phase-out treatment. Confirm the specific cap and expiry for your aluminium sub-entry directly from the Annex of Directive (EU) 2025/2364 before relying on it. Several of these dates fall inside the next twelve months, so the parent entries, which run out earlier than the sub-entries, are the ones to check first.

Note also that entries 6(a)-I, 6(a)-II, 6(b) series, and 6(c) carry a footnote excluding equipment supplied to the general public where an accessible part may be placed in the mouth by children, unless lead release stays at or below 0.05 µg/cm²/h. This connects RoHS directly to REACH restriction logic and is worth flagging for consumer-facing product lines. Managing these thresholds at BOM level through BOM-level compliance tracking prevents a single leaded component from creating category-wide exposure.

RoHS Annex III lead exemptions expiry timeline showing 2027 compliance deadlines

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Industries and Product Categories Affected

The revised RoHS Annex III lead exemptions reach across the full spread of RoHS categories 1 to 11. The exposure is concentrated in:

• Electronics and electrical equipment, where leaded solders and alloys appear across boards, connectors, and assemblies. Certivo's view of electronics manufacturing compliance covers this footprint.

• Semiconductors and microelectronics, affected by the 7(a) die-attach, first-level, and second-level solder joint sub-entries and hermetic sealing. See Certivo's semiconductor and high-tech coverage.

• Passive components and capacitors, tied to the 7(c)-II dielectric ceramic entry.

• Piezoelectric devices, sensors, and PTC ceramics, now covered by the new 7(c)-VI entry.

• Lighting (infrared, HID, and oven lamps) and audio equipment with transducers operating above 200 °C, both named in the 7(a) sub-entries.

• Machined metal parts, fasteners, connectors, aluminium castings, and hot-dip galvanised steel, tied to the 6-series.

• Industrial monitoring and control instruments and medical devices (categories 8, 9, 11), which carry distinct expiry dates and must be tracked separately.

Because the same leaded component can sit in products across several categories with different expiry dates, multi-tier supply chain transparency and accurate material mapping are what keep the re-mapping exercise reliable.

Documentation and Audit-Readiness Challenges

For a compliance engineer, the revised exemptions create a documentation problem before they create a product problem. A generic "RoHS compliant" declaration is now insufficient. You need exemption-specific evidence that names the sub-entry, states the lead concentration, and cites the correct directive.

This surfaces across four audit contexts, and each has different evidence expectations:

• Internal audits need to confirm every leaded component is mapped to a valid current sub-entry.

• Customer audits, typically OEM-driven, increasingly demand the specific Annex III number rather than a blanket statement.

• Regulatory market surveillance by national authorities checks that the exemption relied on actually exists and has not expired.

• Certification audits under ISO 9001, IATF 16949, or ISO 14001 test whether your process for tracking exemption changes is documented and followed.

The harder problem is historic state. When a sub-entry expires or a supplier re-declares, you need to know what was true at the point a product was placed on the market, not only what is true today. That is a data-versioning requirement: immutable, time-stamped declarations with point-in-time retrieval, and a clear evidence chain recording who submitted each declaration, when, and under what authority. No software makes an organisation audit-proof. The realistic objective is audit-ready: fewer surprises and a faster response when an auditor asks for the exemption pack. Building audit-ready documentation across frameworks is what turns a multi-week evidence hunt into a same-day pull.

Compliance Risks and Enforcement Outlook

The near-term risk is not a Commission penalty against your company. It is commercial and operational. Submitting a generic or expired exemption claim to an OEM customer triggers corrective action requests and can lead to supplier disqualification. In a non-transposed market, relying defensively on a new sub-entry before national law reflects it carries legal uncertainty that only local confirmation can resolve.

The forward path is predictable. After the two-month window closes around mid-September 2026, watch for reasoned opinions, which would show a state has not closed its gap. Separately, continued reliance on any of these exemptions beyond 2027 requires a renewal application, and Article 5(5) requires that application at least 18 months before expiry. For the 31 December 2027 sub-entries, that clock is already running. Certivo's guidance on RoHS and REACH compliance action steps for 2026 puts these deadlines in the wider restricted-substances context.

If leaded components sit across multiple product lines and markets, book a compliance risk assessment to map your exemption exposure before the earliest 2027 deadlines.

Strategic Compliance Checklist

1. Identify every product relying on Annex III entries 6(a), 6(b), 6(c), 7(a), or 7(c), especially those placed on the market in Spain, Cyprus, Latvia, Hungary, Malta, Portugal, or Slovakia.

2. Separate the 2025/2364 exposure. Remember that Cyprus and Portugal are not cited for the steel, aluminium, and copper directive.

3. Re-map each exemption claim from the old parent entry to the specific new sub-entry, and flag any application with no remaining cover. This is the substantive work.

4. Update declarations of conformity and technical files to cite (EU) 2025/1802, 2025/2363, and 2025/2364 as the baseline, with the named sub-entry and its expiry date.

5. Diarise the earliest applicable expiry, not the latest. Confirm the 6(b) aluminium caps and dates directly from the directive Annex.

6. Validate national transposition status in the seven states before relying on a new sub-entry defensively in those markets.

7. Monitor for reasoned opinions after mid-September 2026.

8. Prepare renewal applications now where reliance beyond 2027 is required, given the 18-month rule.

Standardising this across plants and regions through consistent compliance processes prevents the re-mapping from being redone product by product.

How AI and Certivo Support RoHS Exemption Management

Re-mapping thousands of components from parent entries to named sub-entries, then tracking staggered expiry dates across categories and jurisdictions, is not sustainable in spreadsheets. This is where an AI-native compliance platform changes the economics.

Certivo functions as the system of record for materials and environmental compliance, linking exemption claims to specific components at BOM level. CORA, Certivo's embedded regulatory intelligence, parses supplier declarations and certificates, flags where a claimed exemption no longer maps to a valid sub-entry, and surfaces the earliest expiry across a portfolio. CORA-powered regulatory intelligence also monitors transposition status and Annex III changes, shifting teams from reactive checks toward continuous, audit-ready readiness.

Automated supplier data collection removes the manual chase for updated declarations, and Certivo's approach means you do not need suppliers to submit disclosures in a rigid format to extract usable data, as explained in why you don't need IPC-1752 format submissions. The result is BOM-level compliance intelligence that answers customer and auditor questions at the product level rather than the company level, with the historic state tracking that audits require.

Executive Conclusion

The 2026 restructuring of the RoHS Annex III lead exemptions is a quiet but consequential shift. The infringement action against seven Member States is the headline, but the work that matters for manufacturers is the re-mapping of every leaded component from a broad parent entry to a specific, dated sub-entry, and the recognition that some applications may now have no cover at all. The obligation applies EU-wide from 1 July 2026 regardless of national transposition, so the correct baseline for your technical files is the EU-level directives themselves.

Teams that treat this as a documentation and data-versioning problem, rather than a one-time update, will absorb the 2027 expiries and future renewals without scrambling. That is precisely the shift from reactive compliance to continuous readiness that an AI-driven compliance backbone is built to support.

To map your leaded components against the revised exemptions and the 2027 deadlines, speak with a compliance specialist.