Date December 12, 2025, Directive (EU) 2025/2456 published in the Official Journal of the European Union. This document amends the RoHS Directive — but does not change the limit, does not add substances, does not expand the scope. It changes evaluation apparatus: transfer the task of scientific and technical assessment to European Chemicals Agency (ECHA).
This is an important change for businesses, because it directly affects two procedures that businesses must use: Please extend the exemption and Restricted substance list review.
1. What happened — in the correct order
| Time | Events |
|---|---|
| October 19, 2021 | The Committee announces the 2022 work program, which outlines plans to amend regulations restricting toxic substances in electronic devices |
| February 14 – March 14, 2022 | Get opinions on impact assessment |
| March 10 – June 16, 2022 | Public consultation on the review of the RoHS Directive; receive 153 comments |
| December 7, 2023 | Committee announced evaluation report RoHS Directive |
| March 15, 2024 | Parliament appoints a rapporteur for the dossier |
| June 14, 2024 | The Council adopted the negotiating stance |
| February 18, 2025 | The Parliament’s Environment Committee (ENVI) passed the report: 71 in favor, 3 against, 7 abstentions |
| April 1, 2025 | Parliament approved the negotiating position |
| June 12, 2025 | The two lawmakers reached a temporary agreement |
| October 21, 2025 | Parliament officially voted: 477 in favor, 93 against, 76 abstaining |
| November 13, 2025 | Council approved |
| November 26, 2025 | Final document signed |
| December 12, 2025 | Published in the EU Official Gazette |
Important note on scope: Committee chose not to rewrite the entire RoHS Directive. The assessment concluded that the Directive generally operates well; The problem lies in the procedure. The legislative response is therefore a targeted amendment, not a new Directive in its place.
2. Why must it be fixed — two weaknesses are named
The Committee’s assessment report identifies two main weaknesses, both of which are directly related to the business’s work:
- Transparency. The exemption decision process and substance list review process are not clear enough to stakeholders.
- Efficiency. Hundreds of exemption requests at the same time, limited assessment resources lead to slow progress. Famously, many extensions were announced as a result next or after old expiration date — creating legal space for businesses using the exemption.
The chosen course of action: placing the technical assessment in the hands of a specialized chemicals agency — ECHA — instead of leaving it to the Commission itself. This is also the spirit of the package “one substance, one assessment” (one substance, one assessment).
3. What does Directive 2025/2456 change?
| Mission | Before | After |
|---|---|---|
| Technical review of requests for time-limited exemptions | The European Commission organizes the assessment (usually through an outsourced consultant) | Switch ECHA |
| Process for reviewing the list of restricted substances (Appendix II) | Committee | Switch ECHA |
This is about change assign tasks. It does not automatically change the list of substances or limits, nor does it change the obligations of businesses.
4. What is NOT changing
- 10 restricted substances and limit 0.1% (cadmium 0.01%) based on homogeneous material: remain the same.
- List of exemptions and deadlines for each item: still decided by separate Authorization Directives — for example, three documents announced on November 21, 2025 updating groups 6, 7(a) and 7(c).
- Corporate obligations: technical dossier, declaration of conformity, CE mark, 10-year record keeping — kept intact.
- Harmonized standards for technical documents: still EN IEC 63000.
- How to prove compliance: still testing, material declaration, supplier records.
5. What else did the EU Council say?
In its stance on the RoHS-related proposal, the EU Council raised two notable points for businesses:
- The committee should Review and revise the list of restricted substances periodically, at least every 5 years, to ensure a high level of protection for human health, the environment and consumer safety.
- The transfer of duties to ECHA will increases the volume and scope of work of ECHA’s scientific committees, and needs stable and capable resources to handle; The Council therefore included a review provision.
Practical implications: The list of 10 substances is not immutable. The 5-year periodic review mechanism is a signal that we should monitor regularly, instead of waiting until there is a new document.
6. How are businesses affected?
| Case | Impact | Things to do |
|---|---|---|
| The business is using the exemption and plans to apply for an extension | The request will be assessed by ECHA instead of the Commission | Prepare a more complete set of technical data: alternatives analysis, reliability data, production volumes, application scope |
| Businesses are dependent on existing exemptions | Do not change immediately; but progress and decision-making may change | Don’t wait for the procedure — there must still be a material conversion plan according to the 2026–2027 deadline |
| Businesses interested in new substances may be limited | Mechanism to review the list of key substances | Monitor information from ECHA in parallel with the Committee; Monitor all dossiers suggesting additional substances |
| Businesses only sell, do not produce | Almost unchanged | Manufacturer’s documentation must still be saved; When there is a change in exemption, documents are required to be updated |
7. What to prepare for an extension request going through ECHA
The rules for submitting requests remain unchanged: no later than 18 months before the expiration date, and in fact most requests are sent through industry associations to have collective weight. But the quality of the documents needs to be higher. Should be prepared:
- Description of specific application — exact to components and functions, not generic descriptions.
- Substitutability data: What materials were tested, what were the results, why did they not meet the requirements (reliability, temperature, longevity, cost, availability).
- Conversion roadmap: specific timelines, technical steps, and barriers.
- Market data: volume of products, number of affected businesses, number of jobs involved.
- Impact analysis if not renewed: risk of loss of production capacity, supply chain disruption, and impact on supporting industries.
This is the type of filing that a single business rarely does well on its own. If you are using a limited exemption in 2026–2027, you should contact your industry association soon, rather than waiting for the deadline.
8. Frequently asked questions
Does Directive 2025/2456 change the limit or add new substances?
No. This is a document on transferring scientific and technical assessment tasks to ECHA. Substance lists and limits remain as current.
Do businesses have to do anything immediately because of this document?
No new obligations arise directly. What needs to be done is Adjust expectations and internal processes: if you are preparing an application for an exemption extension, the application should be prepared in a more rigorous manner; and if you’re tracking the possibility of adding a new substance, the tracking clue now includes ECHA.
Is the EU about to rewrite the entire RoHS Directive?
Not according to this profile. The Committee has evaluated and concluded that the Directive generally operates well; The treatment direction is targeted modification. This is an important difference compared to many rumors in the market about “new RoHS”.
When is the specific application date of the transfer?
The directive has a roadmap for transferring tasks; Detailed application milestones for each procedure should be collated directly in the document on EUR-Lex and followed by official announcements from the Commission and ECHA. As a practical matter, businesses should assume the new requirement will go through ECHA and prepare the corresponding documentation.
Does the 5-year review of the substance list mean more restricted substances are coming?
There are no documents that add new substances. What the EU Council stated is: mechanism: The Committee should review and revise the list at least every five years. This is a risk to monitor, not a change that has occurred.
9. Conclusion
Directive (EU) 2025/2456 is the final result of the RoHS review starting in 2021 — and a Modest in scope but important in operation: technical review of exemptions and review of substance lists moved to ECHA, with the expectation of greater transparency and efficiency.
For businesses, three things to remember: one, limit and 10 constant substances; two, the exemption deadline is still determined by the individual Mandate Directives and the 2026–2027 milestones are still running; three, the substance list will be reviewed periodically so monitoring needs to become a habit, not a one-time event.
References
- Directive (EU) 2025/2456 of the European Parliament and of the Council of 26 November 2025, amending Directive 2011/65/EU on the transfer of scientific and technical tasks to the European Chemicals Agency (published in the EU Official Gazette on 12 December 2025)
- European Parliament — Legislative record: amendments to regulations restricting toxic substances in electronic devices (information updated August 1, 2026)
- European Commission RoHS Directive assessment report, published December 7, 2023
- Communiqués of the European Parliament, June 12, 2025 and October 21, 2025
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Discuss further
Disclaimer
This article is an interpretive content compiled by us; not legal advice. The timelines are stated for reference as of September 28, 2026.
Before applying for a specific application, businesses need to compare the full text of Directive (EU) 2025/2456 and Directive 2011/65/EU (consolidated version) on EUR-Lex, and consult with a recognized testing unit or consultant.
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