For any electrical and electronic equipment (EEE) placed on the EU market in categories 8, 9 or 11, the RoHS exemption 6(a) expiry on 11 December 2026 is a fixed, non-negotiable date. After that day, the broad Annex III exemption that has allowed higher lead content in machining steel and galvanised steel no longer applies to those categories. In its place, two narrower sub-exemptions carry tighter conditions and their own 2027 sunset. Understanding exactly what changes, and what quietly loses coverage, is now a market-access question rather than a paperwork exercise.

This guide sets out the corrected regulatory position, the products affected, and a practical playbook for compliance and CE marking teams. For the wider set of lead exemption changes adopted in the same cycle, the EU RoHS lead exemption shake-up analysis provides the full picture, and the RoHS and REACH compliance lessons for 2026 post covers the broader planning context.

Assess your exposure early: a compliance risk assessment can map which products and parts rely on Exemption 6(a) across your portfolio.

Key Takeaways

• The broad RoHS exemption 6(a) expiry is 11 December 2026 for EEE categories 8, 9 and 11.

• Exemption 6(a) is not renewed; it is replaced by sub-exemptions 6(a)-I and 6(a)-II, both valid only until 30 June 2027.

• The successor threshold for galvanised steel drops from 0.35% to 0.2% lead, and coverage narrows to batch hot-dip galvanised components.

• Applications that fall outside 6(a)-I and 6(a)-II lose their exemption on 11 December 2026, with no replacement.

• Continued market access depends on updated technical documentation and a defensible EU Declaration of Conformity.

• The change is legally set by Commission Delegated Directive (EU) 2025/2364, in force since 11 December 2025.

What Is RoHS Exemption 6(a) and Why Does It Expire on 11 December 2026?

Under the RoHS Directive (2011/65/EU), lead is a restricted substance. Annex II sets the maximum tolerated concentration at 0.1% by weight in homogeneous materials. An application may exceed that limit only where a specific Annex III exemption applies. Exemption 6(a) covered lead as an alloying element in steel for machining purposes and in galvanised steel containing up to 0.35% lead by weight. Importantly, the broad 6(a) entry applied only to categories 8, 9 and 11; categories 1 to 7 and 10 were already covered by the separate 6(a)-I sub-entry.

The change is made by Commission Delegated Directive (EU) 2025/2364, which amends Annex III for lead as an alloying element in steel, aluminium and copper. The directive entered into force on 11 December 2025. The broad 6(a) entry was not renewed and ceases to apply 12 months later, on 11 December 2026. The regulatory basis and the review procedure are documented on the European Commission's RoHS implementation page. For a substance-level view of how these obligations map to products, the RoHS framework overview sets out the exemption logic.

What Replaces Exemption 6(a): The 6(a)-I and 6(a)-II Split

The broad entry is replaced by two narrower sub-exemptions that apply to all EEE categories but with tighter conditions. This is the detail most manufacturers miss, and it is where coverage is silently lost.

Two conditions narrow after the RoHS exemption 6(a) expiry. First, galvanised steel is only covered where it is batch hot-dip galvanised; other galvanising processes fall outside 6(a)-II. Second, the permitted lead content in that galvanised steel drops from 0.35% to 0.2% by weight. Steel used for machining purposes continues to be covered up to 0.35% under 6(a)-I, but only until 30 June 2027. Confirming the exact lead content and process at part level typically requires supplier declarations and mill test reports, as explained in the guide to reading a mill test report.

RoHS exemption 6(a) expiry lowers galvanised steel lead threshold to 0.2 percent

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Who Is Affected: EEE Categories and Product Types

The 11 December 2026 date applies to the broad 6(a) entry, which covered three categories. Category 8 is medical devices. Category 9 is monitoring and control instruments, including industrial monitoring and control instruments. Category 11 is other EEE not covered by categories 1 to 10.

In practice, the exposure sits with manufacturers of medical devices and equipment, laboratory and process instrumentation, and industrial machinery and heavy equipment that contain leaded machining steel or galvanised steel components. Typical affected parts include fasteners, brackets, enclosures, structural steelwork, and free-machining steel components. Because these materials are common and low-visibility, the risk is that they sit unmapped in a bill of materials until the exemption has already lapsed.

The Real Compliance Risk: What Loses Coverage on 11 December 2026

The following applications were covered by broad 6(a) but fall outside both successor sub-exemptions, so they lose their exemption on 11 December 2026 with no replacement:

• Galvanised steel that is not batch hot-dip galvanised, for example electro-galvanised or mechanically galvanised parts in categories 8, 9 or 11.

• Galvanised steel with lead content above 0.2% and up to 0.35%, now above the tightened 6(a)-II threshold.

• Any category 8, 9 or 11 application relying on the broad entry that cannot be reclassified under 6(a)-I or 6(a)-II.

Where no exemption applies and a homogeneous material exceeds 0.1% lead, the product is non-compliant for the EU market. RoHS is enforced by national market surveillance authorities, and penalties are set at Member State level; they can include withdrawal or recall from the market, in addition to financial penalties. The underlying issue is evidentiary: a manufacturer must be able to show, at part level, either that the substance is below the limit or that a valid exemption applies. That is a materials and environmental compliance data problem before it is a legal one.

What EEE Manufacturers Must Do Before the 6(a) Expiry

A structured response reduces the risk of discovering an unmapped leaded-steel part after the deadline. The following sequence is practical for compliance and CE marking teams.

1. Identify reliance. Determine which category 8, 9 and 11 products depend on Exemption 6(a) for leaded machining steel or galvanised steel above 0.1% homogeneous lead.

2. Map at BOM and part level. Link each affected part to its lead content and galvanising method. BOM-level compliance tracking is what makes this reliable across large portfolios.

3. Reclassify. Test each application against 6(a)-I (machining steel up to 0.35%) and 6(a)-II (batch hot-dip galvanised up to 0.2%). Applications that fit are covered until 30 June 2027.

4. Act on the gap. For applications that fit neither, evaluate substitution to below 0.1% lead, a change of galvanising process, redesign, or removal from the EU market.

5. Collect supplier evidence. Gather full material disclosures and mill test reports. Streamlining supplier documentation shortens this cycle, and material data does not need to arrive in a single fixed format, as covered in this note on material disclosures.

6. Update the technical file. Revise the technical documentation and EU Declaration of Conformity so the exemption basis, or the compliant alternative, is defensible.

Struggling to see which parts rely on an expiring exemption? A compliance review can surface leaded-steel exposure across your BOMs before the deadline.

RoHS exemption 6(a) expiry compliance workflow for EEE manufacturers at BOM level

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Timeline: RoHS Lead Exemption Dates You Cannot Miss

This is not a single-deadline story. The successor exemptions expire only months after the 6(a) sunset, so planning should treat 2026 and 2027 as one window.

Because renewal requests and further reviews continue through the RoHS exemption procedure, tracking the status of each entry over time is part of the obligation. Managing compliance risk proactively through regulatory horizon scanning keeps these dates from arriving unannounced.

How Certivo Helps Manage Exemption Sunsets at BOM Level

An exemption sunset is fundamentally a data question: which parts, in which products, rely on a rule that is about to change. Certivo maintains a centralized compliance data backbone that maps substances and thresholds to the bill of materials, so an expiring entry like 6(a) can be traced to the exact parts and products it touches. CORA-powered regulatory intelligence flags exemption status changes as they are adopted, rather than after the deadline.

When a sunset lands, the platform's automated supplier data collection and AI-driven mill test report analysis help confirm lead content and galvanising method at scale, and the evidence is retained in an audit-ready form across frameworks. The goal is not to eliminate compliance risk, which no software can do, but to reduce surprises, speed evidence retrieval, and give CE marking teams a defensible position for the technical file.

The RoHS exemption 6(a) expiry is a clear example of why continuous, BOM-level visibility now outperforms periodic manual reviews. Manufacturers who can see which parts depend on which exemptions, and when those exemptions change, will absorb the 2026 and 2027 lead exemption deadlines without disruption. Those relying on spreadsheets will discover the gaps late.

To evaluate your exposure before 11 December 2026, book a compliance risk assessment and map which products and parts across your portfolio still depend on Exemption 6(a).