If you only read one article about RoHS this year, make it this one. 2025–2027 is the period where RoHS has changed the most since 2019: The EU just extended a series of exemptions with milestones falling in 2026–2027, the EU moved its technical review apparatus to ECHA, and China introduced the RoHS standard for the first time required.
The article summarizes the changes over time, and ends with a to-do list in 2026.
1. Summary table: what milestones, what tasks
| Mold | Change | Who is affected? |
|---|---|---|
| Announced November 21, 2025 | Three Authorization Directives (EU) 2025/2364, 2025/1802, 2025/2363 Update exemption from Annex III on lead (groups 6, 7a, 7c) | Manufacturer uses exemptions: alloys, brass alloys, high temperature welds, glass/ceramic components |
| Announced December 12, 2025 | Instructions (EU) 2025/2456 — transfer the task of scientific and technical assessment to ECHA | The entire business is interested in the exemption process and substance list |
| December 11, 2026 | Expiry of exemptions 6a and 6b-I (groups 1–7, 10) | Hot-dip galvanized steel details; Recycled aluminum contains lead |
| June 11, 2027 | Expiry of exemptions 6b and 6b-II (groups 1–7, 10) | Aluminum alloy contains up to 0.4% lead; Machined and cut aluminum |
| June 30, 2027 | Expired 6a-I, 6a-II, 6b-I/6b-II (industrial group 9, 11), 6b-III, 6c, 7a, 7c-I | Brass alloy ≤ 4% lead; high melting temperature weld; glass/ceramic of components |
| August 1, 2027 | GB 26572-2025 of China takes effect | All electrical and electronic products circulating on the Chinese market, including imported goods |
| December 31, 2027 | Expiration 7a-I to 7a-V; 7c-II; 7c-V; 7c-VI | Semiconductor and die mounting; dielectric ceramic capacitors; PZT/PTC ceramic; functional glass |
2. EU: new limited lead exemption
Three Mandatory Directives adopted by the Commission on September 8, 2025 and published in the EU Official Gazette on November 21, 2025, update three groups of exemptions:
- Group 6 — lead is an alloying element in steel, aluminum and copper alloys. Points of interest: the items are small cup by application (6a-I, 6a-II, 6b-I, 6b-II, 6b-III), and two entries attaching word origin conditions Recycled aluminum contains lead.
- Group 7(a) — lead in high-melting-temperature solder joints (alloys containing 85% or more lead). Original Section 7a expires June 30, 2027; Subsections 7a-I to 7a-V expire December 31, 2027.
- Group 7(c) — lead in glass or ceramic components. Two items completely new are separated: 7c-V (functional glass: high-voltage diode protection, sealing, resistor materials, microchannel plates…) and 7c-VI (PZT ceramic and PTC positive thermal coefficient ceramic).
Things businesses often miss: When the EU splits an old section into multiple subsections, businesses not only have to update deadline date but also need to update correct item number in the technical dossier and declaration of conformity. Writing “7a” when actually using 7a-III will cause the application to be interpreted according to the earliest deadline.
3. EU: ECHA receives technical assessment
Date December 7, 2023, the Commission publishes a report evaluating the RoHS Directive. Conclusion: The directive generally works well, but has two weaknesses — transparency and process efficiency decide on exemption and update the list of substances.
To handle it, the Committee chooses a way do not rewrite the entire Directive, but only transferred the task of scientific and technical assessment European Chemicals Agency (ECHA). This proposal is included in the package “one substance, one assessment” and completed Directive (EU) 2025/2456.
This process goes through all the steps of normal legislative procedures: Parliament approved on October 21, 2025 (477 votes in favor, 93 votes against, 76 abstentions), Council approved on November 13, 2025, document signed on November 26, 2025 and published in the EU Official Gazette on December 12, 2025.
A notable point in the Council’s position: the list of restricted substances should be determined by the Commission reviewed and revised periodically at least every 5 years. Implication: don’t take the current list of 10 substances as immutable. The Council also noted that transferring tasks to ECHA would increase the workload of ECHA’s scientific committees, and would require stable resources to handle them.
4. China: from recommendation to requirement
Date August 1, 2025, China announced GB 26572-2025 — RoHS standard required First, potency August 1, 2027, completely replaces GB/T 26572-2011 (standard recommended).
In the Chinese standards system, “GB/T” is a recommendation — enterprises may not comply; “GB” is mandatory and is the basis for market surveillance and sanctions. Removing the letter “T” means changing the essence, not the words.
Four main contents of the new standard:
- 6 → 10 substances: Add four phthalates DBP, DIBP, BBP, DEHP with limit ≤ 0.1% — similar to EU.
- Uniquely designate the GB/T 39560 series do the test method. This is clearly different from the EU: the EU does not specify just one set of methods.
- Divide into two product groups: Group I (in the list of conformity management) must meet both substance limits and label requirements; Group II only has label obligations.
- Labels become mandatory at national standards level, through content integration SJ/T 11364-2024 — includes the EFUP label and toxic substance declaration sheet.
Small but easily overlooked things: pre-printed label mold. Many factories in Vietnam still use the 6-substance table of the 2011 standard. From 2027, the table must have 10 substance lines.
5. Vietnam: domestic documents are still temporary regulations
On the Vietnamese side, Circular 30/2011/TT-BCT (issued on August 10, 2011) regulations temporary Limit the allowable content of some toxic chemicals in electrical and electronic products. Similar approach to RoHS: limits calculated according to homogeneous material product composition.
Point to note: this is text temporary, came out before the EU added four phthalates and before China moved to a mandatory standard. Therefore, enterprises producing for the domestic market should still compare themselves against international standards if they want to use the same records for many markets.
6. What will NOT change (to avoid worrying too much)
- The limit is still 0.1% (0.01% cadmium alone) calculated accordingly homogeneous material. There are no changes to the limit in the above-mentioned documents.
- The list of substances is still 10 substances. The three Authorization Directives of November 2025 are about exemption, no new substances added. Directive 2025/2456 is about evaluation apparatus.
- Obligation to keep records for 10 years and the CE marking and declaration of conformity obligations remain in effect.
- Harmonized standards for technical documents remains EN IEC 63000.
7. Things to do in 2026 — list of 8 things
- Mapping exemptions: product → components/materials → currently used exemption item → corresponding term (according to the table in section 1).
- Check out the subsection: correctly identify 6a-I/6a-II/6b-I/6b-II/6b-III and 7a-I…7a-V; Check if your PZT or PTC ceramic application is now 7c-V or 7c-VI.
- Update documents and declaration of conformity by new item number — don’t just change the due date.
- Check out these four phthalates if you haven’t tried them before: starting from PVC cables, soft plastic covers, glue, and printing ink.
- Choose a testing room according to the right market: For sale into the EU, IEC 62321 is sufficient; If selling to China, you must ask clearly whether the report cites GB/T 39560 or not.
- Update label mold from 6 to 10 substances for the Chinese market; Check the EFUP label specifications.
- Test run replacement materials 6 months ahead of schedule: Changing materials is not just about changing suppliers, but also having to rerun reliability tests (high temperature, thermal cycling, corrosion).
- Track two sources: exemption information from the European Commission and ECHA; and China’s compliance management list (the list can be expanded, changing product obligations).
8. Frequently asked questions
Will 2026 add new restricted substances?
As of the time of writing, There are no documents that add new substances go to Appendix II. The 2025 changes are to exemptions and to the assessment apparatus. However, both the EU (following the Council’s position) and China have put in place mechanisms to periodically review the substance list — so this is a risk to monitor, not one that has already occurred.
The exemption expires midway, what happens if the goods are in production?
General principle: products that have been placed on the market before the new obligation takes effect can continue to be sold. But time to market must be proven — export records, invoices, delivery dates become important documents. Details are in the article about exemptions from Appendix III.
What should businesses exporting to both the EU and China do first?
Priority according to the nearest milestone: December 11, 2026 (group 6a) — but preparation must begin in 2026. Regarding the dossier, most of the content is shared (list of substances and limits are almost identical); the main difference is specified test method and label request.
Is it necessary to redo all the existing testing?
Not necessarily. If the old report includes all 10 substances (including phthalates) and the sample is representative of the production version, most of the results can be reused. The things that have to be done again are: adding phthalates (if not already there), retesting when changing materials/suppliers, and reporting according to the target market’s specified standards.
If ECHA accepts, will the exemption processing time be faster?
This is the expectation and also the goal of change — but the results cannot yet be confirmed. The EU Council has noted that the transfer of tasks increases the workload of ECHA scientific committees and requires stable resources. Businesses should continue with material conversion plans, not wait for the procedure.
9. Conclusion
2026–2027 is the period does not add new substances, but greatly changes the exemptions, assessment apparatus and legal requirements of the Chinese market.
Four milestones need to be circled in red: December 11, 2026 (6a), June 11, 2027 (6b), June 30, 2027 (6a-I, 6a-II, 6b-III, 6c, 7a, 7c-I and items in groups 9/11), December 31, 2027 (7a-I…V, 7c-II/V/VI) — plus August 1, 2027 for China GB 26572-2025.
The most important thing, and also the most easily procrastinated, is map exemptions for each product. Without that map, it is impossible to know which products must be redesigned, and according to what milestones.
References
- Authorization Directives (EU) 2025/2364, (EU) 2025/1802, (EU) 2025/2363 — published in the EU Official Gazette on 21 November 2025
- Directive (EU) 2025/2456 — transferring scientific and technical tasks to ECHA (signed November 26, 2025, announced December 12, 2025)
- European Commission RoHS Directive assessment report, published December 7, 2023
- European Parliament — Legislative records on amendments to regulations restricting toxic substances in electronic devices (updated August 1, 2026)
- GB 26572-2025 — Requires restrictions on the use of toxic substances in electrical and electronic products (announced August 1, 2025, effective August 1, 2027)
- SGS Safeguards 137/25 (September 18, 2025) about GB 26572-2025
- Circular 30/2011/TT-BCT dated August 10, 2011 of the Ministry of Industry and Trade
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- What is IEC 62321? What parts does the RoHS test method set include and what substances is it used for?
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- What is “homogeneous material”? Misunderstanding this concept is the entire result of RoHS being wrong
- 10 RoHS restricted substances: how do the 0.1% and 0.01% limits apply to “homogeneous materials”?
- Directive (EU) 2025/2456: RoHS moves technical assessment to ECHA — what businesses need to know
- RoHS Annex III exemption: three delegated directives 2025/2364, 2025/1802, 2025/2363 and deadlines 2026–2027
- GB 26572-2025: China’s first mandatory RoHS standard, effective August 1, 2027
- What is RoHS? Complete guide to Directive 2011/65/EU and its 10 restricted substances
Discuss further
Disclaimer
This article is an interpretive content compiled by us; not legal advice. Timelines and content are stated for reference as of September 28, 2026 and may have been updated thereafter.
Before applying to a specific product or shipment, businesses need to compare the verbatim documents on EUR-Lex and the GB 26572-2025 standard, and consult with a recognized testing unit or consultant.
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