Latest EU RoHS Lead Exemption Updates (2025): Full Breakdown for Manufacturers

The use of lead and other hazardous materials in Electrical and Electronic Equipment (EEE) is restricted within the EU under Directive 2011/65/EU, also referred to as the RoHS Directive.

In 2025, the European Commission made significant adjustments to the lead exemption scheme under RoHS. These updates include revocations, renewals with updated expiration dates, and the introduction of new sub-exemptions—primarily concerning the use of lead in alloys, solders, glass, and ceramic components.

Manufacturers, exporters, and suppliers of EEE may be significantly impacted by these modifications, particularly those who rely on lead-containing substances or components that are currently exempt from RoHS restrictions.

What’s New?

The primary updates as of September 2025 are as follows:

1. Lead Exemptions for Alloys (Copper, Steel, and Aluminum)

• Exemption 6(a)—which allowed lead to be used as an alloying element in steel—is revoked, with a 12-month transition period following the Delegated Directive’s implementation.
• The refined subcategories, exemptions 6(a)-I and 6(a)-II, have been renewed and will expire on June 30, 2027.
• Exemption 6(b) (lead in aluminum alloys) is partially revoked; it will soon expire for product categories 1–7 and 10. However, 6(b)-I and 6(b)-II remain in effect for categories 9 IMCI and 11 until June 30, 2027.
• A new exemption, 6(b)-III, has been introduced with an expiration date of June 30, 2027, covering categories 1–10 (excluding 9 IMCI).

2. Lead Exemptions in Solders at High Melting Temperatures

• Exemption 7(a) is renewed through June 30, 2027.
• Newly introduced sub-exemptions 7(a)-I through 7(a)-VII are scheduled to expire on December 31, 2027. These cover highly specific uses, such as die attach, semiconductor manufacturing, and high-temperature interfaces.

3. Lead Exemptions for Glass and Ceramic Components

• The exemption 7(c)-I (lead in glass and ceramic electrical components) is extended until June 30, 2027.
• The exemption 7(c)-II (lead in dielectric ceramic capacitors) is extended to December 31, 2027.
• New categories 7(c)-V and 7(c)-VI (lead in PZT/ceramics and specialty glass materials) expire on December 31, 2027.

4. Deadlines for Transition and Renewal

• Applications for renewal of exemptions expiring on June 30, 2027, must be submitted by December 31, 2025.
• Renewal applications for exemptions expiring on December 31, 2027, must be submitted by June 30, 2026.

The Significance of These Modifications

• Under RoHS, lead in homogeneous materials is restricted to 0.1% by weight, but exemptions allow use where substitution is not yet feasible.
• The revised exemptions reflect growing regulatory pressure to phase out harmful substances.
• Companies must accelerate substitution planning or ensure timely renewal due to shorter review cycles and more narrowly defined sub-exemptions.
• Products that rely on revoked exemptions will no longer be compliant after the phase-out period, jeopardizing EU market access.

Effect on Suppliers and Manufacturers

If you produce, import, or supply EEE (or its components) to the EU market, you should immediately evaluate:

• Which exemptions—including 6(a), 7(a), and 7(c)—your products currently rely on.
• Whether these exemptions are about to expire or be withdrawn. For example, using exemption 6(a) (lead in steel alloys) risks revocation and a 12-month phase-out.
• Substitution options: Begin evaluating lead-free alternatives now, especially for high-risk categories such as alloys, glass/ceramics, and solders.
• Supplier transparency: Ensure suppliers disclose the exemption used, its status, expiration date, and any changes.
• Technical file and due diligence updates: Verify that your RoHS compliance documents align with the latest exemption subcategories and dates.
• Renewal needs: Determine whether you must submit a renewal application (often via trade associations) before the deadlines if your use case still requires an exemption.

What You Need to Do Now

• Step 1: Create an internal inventory of all EEE, raw materials, and components that may contain lead under existing exemptions.
• Step 2: Note each item’s updated expiration date and map it to the relevant exemption number (6(a), 7(a), 7(c), etc.).
• Step 3: Contact your supply chain and request up-to-date declarations confirming exemption numbers, expiration dates, and transition plans.
• Step 4: Begin redesign/substitution planning immediately for products dependent on revoked exemptions.
• Step 5: Ensure your application meets the stricter definitions for renewed exemptions with narrower scopes (e.g., 7(a)-I to 7(a)-VII). Redesign if necessary.
• Step 6: Update your Declaration of Conformity (DoC) and technical documentation with accurate exemption details.
• Step 7: Watch for the publication of Delegated Directives in the Official Journal of the EU (OJEU), as this will initiate the new expiration dates. Continue using current dates for now but prepare for upcoming changes.

Timeline at a Glance

The adoption of these extensive RoHS lead exemption revisions by the EU Commission marks a clear shift: companies must adjust to more specialized sub-exemptions, act faster on substitution, and prepare for shorter exemption lifespans. ComplianceXL supports its clients in preparing for and implementing these regulations in line with the updated scope and timelines.