The RoHS 6(b)-I expiry on 11 December 2026 removes a lead-in-aluminium exemption that many electrical and electronic equipment (EEE) makers and their aluminium-part suppliers have relied on for years. For product categories 1 to 7 and category 10, reliance on exemption 6(b)-I ends on that date. After it, any homogeneous material exceeding the 0.1% lead threshold that was covered only by 6(b)-I is no longer compliant for those categories unless another valid exemption or an alternative alloy applies.

This is a supplier re-certification problem before it is a reporting problem. If you cannot show which parts depend on 6(b)-I, you cannot act on the deadline. Teams that track lead exemptions at the part and material level through a centralized compliance data backbone will move faster than teams working from spreadsheets and email.

Before 11 December 2026: Book a compliance risk assessment to map which parts in your BOMs depend on 6(b)-I and what re-certification each one needs.

What Exemption 6(b)-I Covered

Exemption 6(b)-I of Annex III to the RoHS Directive (2011/65/EU) permits lead as an alloying element in aluminium containing up to 0.4% lead by weight, provided it stems from lead-bearing aluminium scrap recycling. It exists because recycled aluminium feedstock carries residual lead that is difficult to remove, and a strict reading of the RoHS lead restriction would otherwise exclude common recycled-aluminium parts from the EU market.

The exemption sits inside the broader Series 6 “lead as an alloying element” group, alongside 6(a) for steel and 6(c) for copper. Each sub-entry has its own substance scope, concentration limit, and expiry date, which is why BOM substance and threshold management at the material level is essential. A part is not simply “RoHS compliant” or not; it is compliant by reference to a specific exemption with a specific end date.

Commission Delegated Directive (EU) 2025/2364 amended these Series 6 entries. It entered into force on 11 December 2025 and applied from 1 July 2026. For a fuller view of how the Series 6 lead exemptions were split, extended, and revoked across this amendment, see Certivo’s breakdown of the RoHS lead-exemption shake-up.

Who Loses 6(b)-I on 11 December 2026

The directive sets two different expiry dates for 6(b)-I depending on EEE category. The split is the single most important fact for planning.

Expiry split by EEE category

Source: Annex to Delegated Directive (EU) 2025/2364.

The RoHS Annex I categories most affected by the December date include large and small household appliances (1, 2), IT and telecommunications equipment (3), consumer equipment (4), lighting (5), electrical and electronic tools (6), toys and leisure equipment (7), and automatic dispensers (10). If you manufacture or supply into any of these and use recycled-aluminium parts, treat the December date as your working deadline.

⚠️ A documented scope caveat. The annex wording states the 11 December 2026 expiry “for categories 1-7, 10,” while the EU’s own RoHS-2 Exemption Validation and Rolling Plan has prompted differing industry interpretations of 6(b)-I’s historical category coverage. The practical conclusion is the same either way: for categories 1-7 and 10, you cannot rely on 6(b)-I after 11 December 2026. Confirm each part against Annex III and the current Rolling Plan rather than against a summary table. This kind of version-controlled interpretation is where regulatory intelligence and horizon scanning earns its keep.

For manufacturers tracking several lead exemptions at once, Certivo’s EU RoHS framework page consolidates the current requirements and links through to the detailed exemption analyses.

RoHS 6(b)-I expiry split by EEE category showing December 2026 and June 2027 dates

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What Supplier Re-Certification Actually Involves

Re-certification is not a single document. It is a chain of evidence that ties a declared material back to a valid compliance basis. For parts currently resting on 6(b)-I, suppliers need to establish one of three positions: the part no longer uses leaded recycled aluminium, the part qualifies under a successor sub-entry, or the part has moved to an alternative alloy below the 0.1% lead threshold.

The evidence each affected part needs

This is where automated supplier data collection and AI document parsing and certificate validation change the economics. Reading lead content and alloy basis out of mill test reports and material declarations by hand, across thousands of parts, is the bottleneck. Certivo’s approach to mill test report analysis extracts substance data directly from supplier documents so the compliance team reviews exceptions rather than transcribing every line. For the underlying document type, Certivo’s guide to reading a mill test report explains what the lead values mean in practice.

Struggling with supplier lead data across thousands of parts? See how Certivo automates evidence collection — request a compliance review.

Successor Sub-Entries: 6(b)-II and 6(b)-III

Because the brief’s “pending renewal” path does not apply here, the realistic forward options for continued use of leaded aluminium are the neighbouring Series 6 sub-entries, where the use genuinely qualifies. These are not automatic fallbacks; each has its own substance scope and its own expiry.

Source: Annex to Delegated Directive (EU) 2025/2364.

The engineering point for product teams: a recycled-aluminium part that only ever qualified under 6(b)-I does not move to 6(b)-II or 6(b)-III just because they exist. The use case has to match the sub-entry’s wording. Confirming that match is a design-for-compliance decision best made before the part is re-released, which is why connecting compliance data to engineering through a design-through-shipment compliance workflow reduces late surprises.

The Next Expiry Steps After 11 December 2026

The December 2026 date is one step in a tightly sequenced Series 6 timeline. Planning only for 6(b)-I leaves adjacent exposures unmanaged.

Verified Series 6 expiry sequence

Source: Annex to Delegated Directive (EU) 2025/2364; summarised by TÜV Rheinland.

Treating these as a single wave rather than three separate fire drills is the difference between a managed transition and repeated last-minute scrambles. Continuous compliance monitoring against the current exemption schedule, rather than an annual manual review, is what keeps the June 2027 dates from becoming the next emergency. Certivo’s broader view on moving from reactive to continuous readiness sets out why.

Business and Supply Chain Impact

For a board or a CFO, the exposure is market access, not a line-item fine. A part that loses its exemption basis and is placed on the EU market in a non-compliant state is subject to market-surveillance action, potential withdrawal, and customer rejection. For a Tier 1 supplier, an incomplete re-certification can stall an OEM’s own RoHS declaration and trigger line holds.

The practical impact concentrates in four places:

• Affected products. Any EEE in categories 1-7 or 10 containing recycled-aluminium parts whose only compliance basis was 6(b)-I.
  
  

• Supplier dependency. Re-certification depends on sub-tier data you may not hold today, making multi-tier supply chain transparency the gating factor.
  
  

• Audit readiness. Customer audits and market-surveillance requests will ask for the compliance basis of specific parts on specific dates, which requires time-stamped, point-in-time evidence rather than a current snapshot.
  
  

• Lead time. Alloy substitution, re-testing, and supplier re-declaration can run months, not weeks.

Linking exemption status to the bill of materials is what makes this answerable. With BOM-level compliance intelligence, a query like “show every finished product containing a part that depends on 6(b)-I” returns an answer instead of launching a two-week investigation. Certivo’s work on automating multi-tier compliance across global suppliers describes how that data is assembled.

A Re-Certification Readiness Checklist

A practical sequence for the weeks before 11 December 2026:

✅ Scope the exposure. Identify every part and homogeneous material whose RoHS basis is 6(b)-I, filtered to categories 1-7 and 10.

✅ Prioritise by category. Separate the December 2026 population (cats 1-7, 10) from the June 2027 population (cat 9 IMCI, 11).

✅ Request current material data. Collect updated lead concentrations and alloy/sourcing basis from affected suppliers.

✅ Test each part against a valid basis. Determine whether it drops below 0.1% lead, qualifies under 6(b)-II or 6(b)-III, or needs substitution.

✅ Refresh declarations. Obtain updated supplier declarations citing the correct current exemption or sub-threshold status through streamlined supplier documentation.

✅ Preserve the evidence chain. Retain time-stamped declarations so a future audit can see the compliance basis as it stood on any given date.

RoHS 6(b)-I supplier re-certification workflow from part identification to updated declaration

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How AI-Native Compliance Shortens the Re-Certification Cycle

The constraint on a deadline like this is almost never the regulation. It is the time it takes to find the affected parts, read the supplier evidence, and re-issue clean declarations. Those are data problems, and they are where AI-native compliance automation applies directly.

Certivo serves as the system of record for exemption status at the part and material level, and CORA, its embedded intelligence, does the reading and matching work. CORA-powered regulatory intelligence tracks exemption schedules such as the Series 6 sequence and flags affected parts before the date arrives rather than after. CORA-enabled analysis parses lead values and alloy basis out of mill test reports and material declarations, validates them against the applicable sub-entry, and surfaces only the parts that need human judgment.

The outcome is not a claim that software removes compliance risk. It is faster evidence retrieval, earlier visibility of exposure, and shorter response time to customer and market-surveillance requests. That shift from reactive scramble to continuous audit-ready documentation is the point. For the wider case, see Certivo’s guide to AI tools for compliance management.

Get complete visibility into your 6(b)-I exposure before the deadline. Speak with a compliance specialist.