The European Union has introduced changes to several lead exemptions under the Restriction of Hazardous Substances (RoHS) Directive (2011/65/EU). These changes affect the use of lead in specific materials and components used in electrical and electronic equipment (EEE).
With the revised requirements applying from 1 July 2026 and the first exemption expiry approaching, manufacturers and suppliers should review their product compliance and supply-chain documentation.
Which exemptions are affected?
Three Commission Delegated Directives introduce changes to specific RoHS exemptions:
Lead in steel, aluminium and copper alloys – Directive (EU 2025/2364)
Exemptions 6(a), 6(b) and 6(c) cover lead used as an alloying element in steel, aluminium and copper alloys. Their expiry dates are:
- 11 December 2026: Exemption 6(a), covering machining steel and galvanised steel.
- 11 June 2027: Exemption 6(b), covering aluminium, subject to separate provisions for certain applications.
- 30 June 2027: Exemption 6(c), covering copper alloys containing up to four percent lead.
Additional sub-exemptions cover specific steel and aluminium applications, with separate expiry dates depending on the application and EEE category.
Lead in high-melting-temperature solders — Directive (EU) 2025/1802
From 1 July 2026, exemption 7(a), covering solders containing at least 85% lead by weight, is divided into seven application-specific sub-exemptions. These cover uses including semiconductor interconnections, the process of die attachment[JS1] [JB2] , solder joints, hermetic sealing, certain lamps, and high-temperature audio transducers. The original exemption expires on 30 June 2027, while the sub-exemptions generally expire on 31 December 2027. The provisions apply across relevant EEE categories, excluding applications covered by exemption 24, and are subject to specific technical conditions.
Lead in glass and ceramic components — Directive (EU) 2025/2363
The changes apply from 1 July 2026, revising exemptions 7(c)-I and 7(c)-II and introducing two new exemptions: 7(c)-V for specific glass applications and 7(c)-VI for certain ceramic applications.
These exemptions cover uses such as piezoelectric devices, high-voltage components, hermetic sealing, resistive glass materials, lead zirconium titanate (PZT) ceramics, and positive temperature coefficient (PTC) ceramics.
Key expiry dates:
- 30 June 2027: Exemption 7(c)-I.
- 31 December 2027: Exemptions 7(c)-II, 7(c)-V and 7(c)-VI.
What should businesses do?
Manufacturers, importers, and suppliers should identify affected products, verify eligibility under the revised exemption wording, obtain updated supplier declarations, assess alternative materials where necessary, and update compliance records ahead of the relevant deadlines.
Early reviews are worth it
Early review of product composition, supplier documentation, and exemption eligibility can help businesses manage regulatory changes, reduce supply-chain disruption, and maintain compliance with EU RoHS requirements.
