Under the EU RoHS Directive (2011/65/EU), Lead (Pb) is one of the most tightly regulated substances due to its toxicity and environmental impact. However, the directive recognises that lead is still technically necessary in certain applications where reliability, safety, or performance cannot yet be achieved with lead-free alternatives.
These permitted uses are listed under Annex III, which covers exemptions applicable to most categories of electrical and electronic equipment (EEE). Each exemption is time-limited and subject to periodic review. Several Annex III lead exemptions are scheduled for review, expiry, or renewal decisions around 2026–2027, making this a critical compliance milestone for manufacturers.
Key Challenges Ahead of the 2026 Review Cycle
The approaching review period presents multiple challenges for companies relying on Annex III lead exemptions:
- Uncertainty over renewals: Not all lead exemptions are guaranteed to be renewed
- Technical dependence: Lead is still widely used in solders, glass, ceramics, and high-reliability components
- Long redesign timelines: Transitioning to lead-free alternatives may require years of testing, qualification, and certification
- Supply chain opacity: Limited visibility into where exemptions are used within components or sub-assemblies
Major Annex III Lead Exemptions to Monitor
1. Lead in High-Temperature Solders
Exemption 7(a)
- Lead content >85% in high melting temperature solders
- Used in power electronics, industrial equipment, and high-reliability assemblies
- Risk factor: Continued pressure to demonstrate lack of viable alternatives
2. Lead in Glass of Electronic Components
Exemption 7(c)-I
- Lead in glass of electronic components (excluding capacitors)
- Used in semiconductors, diodes, resistors, and IC packaging
- Risk factor: Broad usage but increasing scrutiny as material science advances
3. Lead in Ceramic Parts (e.g., Piezoelectric Devices)
Exemptions 7(c)-I & 7(c)-IV
- Includes lead zirconate titanate (PZT) in sensors, actuators, and transducers
- Common in industrial, medical, and automotive EEE
- Risk factor: Limited high-performance substitutes for certain applications
4. Lead in Dielectric Ceramic in Capacitors
Exemption 7(c)-II
- Lead-containing ceramic materials in capacitors
- Used where size, stability, and reliability are critical
- Risk factor: Alternatives exist for some uses, but not all performance classes
5. Lead in Solder for Servers, Storage, and Networking Equipment
Exemptions 7(a), 7(c)-I (application-dependent)
- Used to ensure long-term reliability and thermal performance
- Risk factor: Increasingly tied to category-specific justifications
Current Structured Expiry (Selected)
| Exemption | Application | Expiry |
| 7(a) | General HMP solder | 30-Jun-2027 |
| 7(a)-I to VII | Defined technical applications | 31-Dec-2027 |
| 7(c) | Generic glass & ceramic components | 30-Jun-2027 |
| 7(c)-I | Dielectric ceramic capacitor | 31-Dec-2027 |
| 7(c)-V | Functional leaded glass | 31-Dec-2027 |
| 7(c)-VII | Lead-based ceramics (PZT/PTC) | 31-Dec-2027 |
6. Lead in Bearings and Machined Components
Exemptions 6(a), 6(b), 6(c)
- Lead used as an alloying element in steel, aluminium, or copper alloys
- Supports machinability and wear resistance
- Risk factor: Substitution possible in some cases, increasing review pressure
| Exemption | Application | Expiry |
| 6(a) | Lead in steel | 11-Dec-2026 |
| 6(b) | Lead in aluminium (general) | 11-Jun-2027 |
| 6(b)-I/II | Aluminium alloys (specific categories) | 30-Jun-2027 |
| 6(b)-III | Recycled aluminium casting alloys | 30-Jun-2027 |
| 6(c) | Lead in copper alloys (≤4%) | 30-Jun-2027 |
Recommended Compliance Actions
A structured, forward-looking compliance strategy is essential ahead of the 2026 Annex III updates. Key steps include:
- Mapping all Annex III lead exemptions across product portfolios
- Identifying expiry dates and review status
- Assessing feasibility of lead-free alternatives
- Engaging suppliers early to confirm exemption usage
- Preparing redesign or requalification plans for high-risk exemptions
- Monitoring EU evaluation reports and stakeholder consultations
These actions help determine whether continued use of lead remains justified from a regulatory perspective.
Why Early Preparation Matters
Proactively addressing Annex III lead exemptions before 2026 offers clear advantages:
- Regulatory stability: Reduced risk of last-minute non-compliance
- Operational continuity: Avoid unexpected product disruptions
- Cost efficiency: Prevent emergency redesign costs
- Improved sustainability performance: Supports ESG commitments
- Stronger customer trust: Demonstrates long-term compliance readiness
Even where exemptions are renewed, validity periods may be shortened or additional conditions introduced.
RoHS exemptions are temporary. Maintaining a BoM-level exemption register and expiry tracker ensures updates do not become last-minute non-conformances.
The upcoming review and expiry cycle for EU RoHS Annex III lead exemptions (2025–2027) represents a major compliance checkpoint for manufacturers. Companies relying on these exemptions must strengthen visibility across their product portfolios, engage suppliers early, and evaluate substitution pathways where feasible.
ComplianceXL assists global manufacturers in managing product environmental compliance, with a strong focus on EU RoHS exemptions and restricted substances. Our specialists help identify the correct exemption sub-entries, verify category scope, and track expiry timelines so that technical documentation, declarations, and certificates remain aligned with regulatory expectations.
Early planning and structured exemption management will help organizations maintain EU market access, avoid disruptions, and align with long-term sustainability goals.
FAQs:
1. What is Annex III under RoHS?
Annex III lists substance exemptions applicable to most categories of EEE, including several exemptions for lead use in specific applications.
2. Are all Annex III lead exemptions expiring in 2026?
No. Only certain exemptions are scheduled for review or expiry around 2026. Each exemption has its own validity period.
3. What happens if a lead exemption is not renewed?
If an exemption expires without renewal, the use of lead for that application becomes non-compliant in the EU.
4. Can companies request renewal of Annex III lead exemptions?
Yes. Manufacturers or industry groups can submit renewal applications, but approval depends on technical justification and availability of alternatives.
5. Should companies plan substitution even if an exemption may be renewed?
Yes. Renewal periods may be shortened and future reviews stricter, making early substitution planning a best practice.
