Date November 21, 2025, announced by the European Commission three Authorization Directives Bulk update of exemptions about lead in Annex III of the RoHS Directive. The new expiration date falls on December 11, 2026, June 30, 2027 and December 31, 2027 — meaning the business is relying on a yes exemption less than 15 months to prepare.
This article fully lists the newly extended exemptions, the new deadline for each item, and what businesses must do according to each milestone.
1. What is the RoHS exemption and why does it still exist?
RoHS sets limits for 10 substances, but for some applications not yet reliable replacement material — or technically replaceable material that compromises product reliability, longevity, or safety. Therefore, the Directive has a mechanism exemption (exemption): allows exceeding the limit in a specific application, within a specific time limit.
| Appendix III | Appendix IV | |
|---|---|---|
| Apply for | Groups 1–7, 10 and 11 | Group 8 (medical equipment) and group 9 (monitoring – control) |
| Typical example | Lead in high-melting solder joints, lead in brass alloys, lead in glass/ceramic components | Lead in some components used for medical equipment and specialized measuring equipment |
Exemption not the default permission. Businesses that want to use it must: (1) correctly identify the exemption section that applies to their product, (2) clearly state that exemption section in the technical dossier and declaration of conformity, and (3) monitor the expiration date of that section to have a solution before its expiration.
Exemption mechanism exists Maximum lifespan 5 years for each extension (in some special cases it may be longer), and renewed in installments. The process includes: business or industry association submits request for extension → Commission hires independent research to evaluate → draft Authorization Directive → Parliament and Council review → publication in the EU Official Gazette. Businesses are advised to submit a request no later than 18 months before the expiration date — this is the reason why many exemptions are extended so closely, even after the old deadline.
2. Three Authorization Directives have just been announced
Three documents were approved by the Committee today September 8, 2025 and published in the EU Official Gazette on November 21, 2025:
| Text | Update exemption group | Content |
|---|---|---|
| (EU) 2025/2364 | Group 6 (6a, 6b, 6c) | Lead is an alloying element in steel, aluminum and copper alloys |
| (EU) 2025/1802 | Group 7(a) | Lead in high melting point solder (alloy containing ≥ 85% lead) |
| (EU) 2025/2363 | Group 7(c) | Lead in glass or ceramics of electrical and electronic components |
3. Group 6 — lead in steel, aluminum, copper alloys: (EU) 2025/2364
| Section | Exempt content | New deadline |
|---|---|---|
| 6a | Lead is an internal alloying element steel for cutting and machining and in hot-dip galvanized steel, containing a maximum of 0.35% lead by mass | December 11, 2026 |
| 6a-I | Lead is an alloying element in cutting steel that contains a maximum of 0.35% lead | June 30, 2027 (all groups) |
| 6a-II | Lead in the details hot-dip galvanized steel in batches Contains a maximum of 0.2% lead | June 30, 2027 (all groups) |
| 6b | Lead is an internal alloying element aluminum Contains a maximum of 0.4% lead | June 11, 2027 |
| 6b-I | Lead in aluminum (≤ 0.4%) with conditions Derived from recycled aluminum containing lead | December 11, 2026 (groups 1–7, 10); June 30, 2027 (industrial group 9, group 11) |
| 6b-II | Lead in aluminum used for cutting and machining, lead content up to 0.4% | June 11, 2027 (groups 1–7, 10); June 30, 2027 (industrial group 9, group 11) |
| 6b-III | Lead in cast aluminum alloy contains a maximum of 0.3% lead, provided that it is sourced from lead-containing recycled aluminum | June 30, 2027 (groups 1–8, group 9 not industrial monitoring and control equipment, group 10) |
| 6c | Copper alloys contain a maximum of 4% lead by volume | June 30, 2027 |
How to read this table: This is an exemption group that affects the precision mechanical industry — turning parts, screws, connectors, brass parts. The notable new point is that the items are small cup by application (6a-I, 6a-II, 6b-I, 6b-II, 6b-III), of which two items attach the condition “derived from recycled aluminum”. Splitting helps the unit to renew later more accurately, but also forces the business to Identify the correct subsection I’m using it – using the wrong subsection means the profile is wrong.
4. Group 7(a) — high fusion welds: (EU) 2025/1802
| Section | Exempt content | New deadline |
|---|---|---|
| 7a | Lead in high melting temperature type welds (lead alloy containing 85% lead or more) | June 30, 2027 (all groups, except applications in section 24 of Annex III) |
| 7a-I | High melting point welds for internal connection when mounting die or mounting the die with other components in a semiconductor assembly, with steady/pulsed current ≥ 0.1 A, or blocking voltage above 10 V, or die edge size larger than 0.3 mm × 0.3 mm | December 31, 2027 |
| 7a-II | High melting point welds for mold-mounted integrated connector in components, when the mold mounting material after curing/sintering reaches: thermal conductivity > 35 W/(m·K), electrical conductivity > 4.7 MS/m, solidus temperature higher than 260 °C | December 31, 2027 |
| 7a-III | High melting point welds first floor weld (internal or integrated connection) to manufacture components, so that when attaching components to the board by second-layer soldering, the first-layer solder joints do not reflow. Not applicable for mold mounting and sealing | December 31, 2027 |
| 7a-IV | High melting point welds second floor weld When mounting components on a printed circuit board or frame: (1) in a solder ball to mount a ceramic BGA; (2) in molded parts covered with high temperature resistant plastic (> 220 °C) | December 31, 2027 |
| 7a-V | High melting point welds made sealing material middle: (1) ceramic case or ceramic button with metal case; (2) component connector to internal sub-component | December 31, 2027 |
How to read this table: “original” section 7a — the broadest version — expires sooner (June 30, 2027) compared to subsections 7a-I to 7a-V (December 31, 2027). In fact, most specific use cases fall into one of five subsections; But if the enterprise only writes “apply 7a” in the records, the application milestone will be understood as the earliest milestone. This is a very easy and costly filing error.
5. Group 7(c) — lead in glass or ceramics: (EU) 2025/2363
| Section | Exempt content | New deadline |
|---|---|---|
| 7c-I | Electrical and electronic components contain lead glass or ceramic other than dielectric ceramics in capacitors — for example piezoelectric devices — or in glass/ceramic substrate compounds | June 30, 2027 (all groups) |
| 7c-II | Lead in dielectric ceramic of capacitor has a rated voltage of 125 V AC or 250 V DC or more | December 31, 2027 (all groups, except applications falling under 7c-I or 7c-IV) |
| 7c-V (new item) | Components containing lead inside glass or glass-based compound when undertaking one of the following functions: (1) protection and insulation in the glass ball of the high-voltage diode and the glass layer for the wafer; (2) sealing between ceramic, metal and/or glass parts; (3) bonding in the parameter window below 500 °C with viscosity 1013.3 dPa·s; (4) making ink-like resistive materials, resistivity from 1 ohm/square to 100 megohm/square (except trimmer potentiometer); (5) for chemically modified glass surfaces in microchannel plates (MCPs), channel electron multipliers (CEMs), and resistive glass products (RGPs). | December 31, 2027 (all groups) |
| 7c-VI (new item) | Components containing lead inside ceramic when performing functions: (1) used in lead zirconate titanate (PZT) piezoelectric ceramics; (2) or give ceramics a positive thermal coefficient (PTC) | December 31, 2027 (all groups, except applications in 7c-II, 7c-III, 7c-IV and section 14 of Appendix IV) |
The most important point of this text alone: two items 7c-V and 7c-VI are Brand new item, separated from old section 7c-I. That means businesses previously used “7c-I” for PZT or PTC ceramic applications must switch to the correct new entry on file — not just updating the due date.
6. Three milestones must be circled in red
| Mold | Expired items | Product groups are directly affected |
|---|---|---|
| December 11, 2026 | 6a; 6b-I (groups 1–7, 10) | Hot-dip galvanized steel details; Recycled aluminum contains lead |
| June 11, 2027 | 6b; 6b-II (groups 1–7, 10) | Aluminum alloy contains up to 0.4% lead; Machined and cut aluminum |
| June 30, 2027 | 6a-I; 6a-II; 6b-I (industrial group 9, 11); 6b-II (industrial group 9, 11); 6b-III; 6c; 7a; 7c-I | Brass alloy ≤ 4% lead; high melting point weld; glass/ceramic of components |
| December 31, 2027 | 7a-I to 7a-V; 7c-II; 7c-V; 7c-VI | Semiconductor and die mounting; dielectric ceramic capacitors; PZT; PTC ceramic; functional glass |
If you can only remember one sentence: Groups 6 and 7a/7c-I are the most urgent groups, due in mid-2027; Groups 7a-I–V and 7c-II/V/VI have one more year, until the end of 2027.
7. What must businesses use exemptions — checklist by milestone
- Check all products you are using for exemption and create a table: product → components/materials → exemption item currently recorded in the file → corresponding new deadline.
- Check out the subsection. For groups 6a/6b/6c and 7a, determine which parent or subsection the business falls into. Original item expires sooner.
- Update technical documents and declaration of conformity under the new section (especially if your application is now covered by 7c-V or 7c-VI).
- Ask the component supplier in writing: which exemptions they are relying on, and what their transition plans are.
- Check inventory and production plans compared to the deadline: which batch is produced before the expiration date, which batch is after the expiration date.
- Prepare at least 6 months ahead of schedule: Find alternative materials/coatings/alloys, run reliability tests (high temperature, thermal cycling, corrosion) before changing production materials.
- If necessary, apply for a further extension: Requests should be submitted through the industry association or directly to the Commission no later than 18 months before the expiration date — which means the 2027 window will begin to close.
- Record the decision: If you choose to continue using a restricted substance beyond the expiration date while waiting for an extension, the rationale and risks must be clearly documented — as the ultimate responsibility lies with the manufacturer of the product.
8. What if it expires and cannot be replaced?
Four common situations and how to handle them:
| Situation | Correct understanding |
|---|---|
| The product has been launched into the EU market before expiration date | General principle of RoHS: products placed on the market before a new obligation takes effect can continue to be sold. But time-to-market must be proven — this is where export records and invoices become important. |
| Waiting for the next extension, the old deadline has passed | This is a legal gap that has occurred with many exemptions. Enterprises should have internal written explanations and legal advice, and should not assume “will be renewed”. |
| Spare parts for sold equipment | RoHS has separate regulations for replacement parts, allowing exemptions in some cases to ensure repairability. Conditions are very specific, need to compare verbatim. |
| There are no alternatives, no exemptions | Must redesign or accept not being able to bring that product to the EU market. There are no shortcuts. |
9. Why is the extension progress slow — and ECHA will take over from 2026
The Committee itself, in its RoHS assessment report published December 7, 2023, concluded that the Directive generally worked well but pointed out two weaknesses: transparency and process efficiency decide on exemptions and update the list of restricted substances. With hundreds of renewal requests at the same time and limited resources, many renewals are delayed compared to the old deadline.
To handle this, the Committee has proposed Transfer the task of scientific and technical assessment to the European Chemicals Agency (ECHA). This proposal is part of the “one substance, one assessment” package and has been completed Directive (EU) 2025/2456 (signed November 26, 2025, published in the EU Official Gazette on December 12, 2025). This is about change evaluation apparatus, without changing the limit or substance list.
Practical implications for businesses: the exemption mechanism may still be slow, but the trajectory of extension requests will change. Businesses should monitor information from ECHA in parallel with the Committee.
10. Frequently asked questions
Is the exemption date stated in the Directive the date by which I must stop delivering goods?
Not quite. The exemption deadline is the point from which the product is placed on the EU market first time must comply with quality limits. Products that were validly placed on the market before that milestone will continue to be sold, but the time of introduction to the market must be proven.
Does the exemption automatically apply to my product?
No. You must identify the correct exemption that applies to the specific application, and clearly state it in the technical documentation and declaration of conformity. Using an exemption without recording it in the record is an invalid record.
Can multiple exemptions be used for one product?
Yes, if different components/materials actually fall under different exemption categories. In that case, the dossier must list each item according to each material.
Have the three Directives 2025/2364, 2025/1802 and 2025/2363 taken effect yet?
This is the EU Delegation Directive; Following publication in the EU Official Gazette, new exemptions and new deadlines apply. As a manufacturer or importer, the mold that needs to be managed is term of each exemption item (table in section 6).
How do I know which exemption my product is relying on?
The quickest way is to ask the parts and materials supplier — but the answers are often incomplete. The sure way is to compare your material/coating/alloy with the content of each exemption item, and compare it with RoHS test results to know which homogeneous material exceeds the limit.
11. Conclusion
Three Authorization Directives have just been announced no expansion RoHS scope and Do not add new substances — they extend and restructure the lead exemption, with focused deadlines December 11, 2026, June 11, 2027, June 30, 2027 and December 31, 2027.
What needs to be done is very specific: Review which exemptions your product falls under, check the new subsections (especially the recently separated 7c-V and 7c-VI), update your records, and begin a material conversion plan at least 6 months ahead of schedule. For groups 6 and 7a, the clock is running.
References
- Delegation Directive (EU) 2025/2364 — amending Annex III, exemption groups 6a, 6b, 6c
- Delegation Directive (EU) 2025/1802 — amending Annex III, exemption group 7(a)
- Delegation Directive (EU) 2025/2363 — amending Annex III, exemption groups 7(c)-I, 7(c)-II; supplement 7(c)-V and 7(c)-VI
- Report of the European Commission on the review of the RoHS Directive, published 7 December 2023
- Directive (EU) 2025/2456 — transfer of scientific and technical tasks to ECHA
- European Commission — official page about the RoHS Directive (accessed September 28, 2026)
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Discuss further
Disclaimer
This article is an interpretive content compiled by us; not legal advice. The content of the exemption items is summarized from the original text and may be shortened in expression compared to the original text.
Businesses using the RoHS exemption should check the full text of Annex III of Directive 2011/65/EU (the latest consolidated version) on EUR-Lex, and consult with an accredited testing or consultant before applying to a specific product.
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