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) 2. Lead Exemptions in Solders at High Melting Temperatures 3. Lead Exemptions for Glass and Ceramic Components 4. Deadlines for Transition and Renewal The Significance of These Modifications Effect on Suppliers and Manufacturers If you produce, import, or supply EEE (or its components) to the EU market, you should immediately evaluate: What You Need to Do Now Timeline at a Glance Exemption Status Expiry 6(a) – Lead in steel alloys Revoked 30 June 2027 6(a)-I / 6(a)-II Renewed 30 June 2027 6(b) – Lead in aluminium alloys Part-revoked / Part-renewed 30 June 2027 / earlier for certain categories 6(c) – Lead in copper alloys Renewed 31 Dec 2026 (or 30 June 2027 depending on source) 7(a) – Lead in high-melting solders Renewed 30 June 2027 7(a)-I to VII New more specific solders exemptions Introduced 31 Dec 2027 7(c)-I, 7(c)-V – Lead in glass materials Renewed / introduced 30 June 2027 / 31 Dec 2027 7(c)-II, 7(c)-VI – Lead in dielectric ceramic capacitors / PZT ceramics Renewed / introduced 31 Dec 2027 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.
Hexavalent Chromium in Focus: Get the latest EU RoHS Exemptions
Numerous hazardous substances are prohibited in electrical and electronic equipment (EEE) under the EU RoHS directive, aimed at safeguarding the environment and human health. RoHS 2.0 replaced the original RoHS directive (2002/95/EC) in 2003, following its recasting in July 2011 (2011/65/EU). Member states will commence applying the new exemptions from September 1, 2023. However, specific applications or industries are granted exemptions from RoHS requirements, which come with designated expiration dates. To ensure complete adherence to regulations, industries must identify suitable alternative technologies or materials during the exemption period. On October 28, 2022, the European Commission introduced exemptions to the EU RoHS Directive, affecting businesses that utilize hexavalent chromium. These exemptions permit limited use of hexavalent chromium in certain applications, despite its hazardous nature. To maintain compliance with the directive, companies must both abide by the regulations and adhere to the outlined conditions of the exemptions. For a detailed list of changes, refer to: COMMISSION DELEGATED DIRECTIVE (EU) 2023/171 The updated “9(a)-III” exemption now pertains to Category 1 Large Appliances and remains valid until December 31, 2026. This exemption allows the utilization of up to 0.7 percent by weight of hexavalent chromium as a corrosion inhibitor in the working fluid of carbon steel closed circuit gas absorption heat pumps. Member states will begin accepting applications for the new exemptions from September 1, 2023. It’s crucial to note that information concerning RoHS exemptions may evolve with time, potentially leading to the addition of new exemptions or the revision of existing ones. Manufacturers and businesses impacted by RoHS should consistently monitor the latest updates from the European Commission to ensure ongoing compliance. This vigilance ensures alignment with the current regulations. Exemptions within the EU RoHS Directive affecting companies using hexavalent chromium were introduced by the European Commission (EC) on October 28, 2022. At ComplianceXL, our dedicated team remains committed to delivering the latest news on EU RoHS and regulatory compliance that could influence your business operations. We furnish dependable information and insights, empowering you to remain informed and make well-informed decisions. Furthermore, our team is poised to assist you in devising strategies for complete compliance with all relevant regulations.Contact us today for more information!
EU to add two new substances to RoHS list
History of RoHS directive European union realizes the need of Restriction of Hazardous Substances(RoHS) directive for electronics industry and many electrical products. Initially RoHS Directive 2002/95/EC was originated in 2002 and restricted 6 hazardous substances in the list for all electrical and electronic products in the EU market from 1st of July 2006 must pass RoHS compliance. Cadmium (Cd): < 100 ppm Lead (Pb): < 1000 ppm Mercury (Hg): < 1000 ppm Hexavalent Chromium: (Cr VI) < 1000 ppm Polybrominated Biphenyls (PBB): < 1000 ppm Polybrominated Diphenyl Ethers (PBDE): < 1000 ppm In 2011, Directive 2011/65/EU was published and called RoHS 2 with addition of Categories 8 and 9 and CE marking requirements on all the applicable products. In 2019, Directive 2015/863 published RoHS 3 restricted 4 more Phthalates totaling the substances to 10. Bis(2-Ethylhexyl) phthalate (DEHP): < 1000 ppm Benzyl butyl phthalate (BBP): < 1000 ppm Dibutyl phthalate (DBP): < 1000 ppm Diisobutyl phthalate (DIBP): < 1000 ppm New proposed update to RoHS list In Q2 2022, a public consultation was raised to restrict two more substances as per report by the Oeko-Institut which has been appointed by the European Commission. The recommended substances for addition are: Tetrabromobisphenol A (TBBP-A): Tetrabromobisphenol A (TBBP-A) with CAS number 79-94-7 is a brominated flame retardant. The hazardous impacts to human body includes endocrine disrupter and immunotoxicant. The commercial use of TBBP-A as in manufacturing of of brominated epoxy resins, additive for flame retardant in thermoplastics. Medium Chain Chlorinated Paraffins (MCCPs): Medium-chain chlorinated paraffins (MCCPs) with CAS number 85535-85-9 is also an flame-retardant has similar applications of TBBP-A also used as insulations, flexible property applications like cables and wire insulations. If the proposal is accepted after public consultation by EU commission the existing list will scale from 10 to 12 substances. This implementation will impact in larger way to most of the existing electronic and electric industries as flame retardant cable/wire/plasticizers are the basic building blocks for safety issue. To know more, please talk to one of our RoHS specialists today!
All you need to know about New RoHS Project (Pack 25)
Oeko-Institut has been appointed by the European Commission to assist in reviewing requests for exemptions of Restricted Substances under the Directive 2011/65/EU, commonly known as RoHS 2. The purpose of this consultation is to collect contributions from stakeholders. Oeko is responsible for collecting and evaluating information provided by Stakeholders, whereas institutions of the European Union are solely responsible for making decisions. The Oeko-Institut has begun assessment of the two exemption requests for the new RoHS project – pack 25. Below are the exemptions requests raised with the EU for the RoHS Directive: Mercury in pressure transducers (Mercury in melt pressure transducers for capillary rheometers at temperatures over 300°C) DEHP in a PVC base material (Bis (ethylhexyl) phthalate (DEHP) as a plasticizer in polyvinyl chloride (PVC), is used to produce amperometric, potentiometric and conductometric electrochemical sensors, which are used in medical devices for the analysis of whole blood (i.e. in-vitro diagnostic medical devices). This study will provide information on exemption requests for two new exemptions that will be listed in Annex IV of Directive 2011/65/EU. It is important to note that this list of exemptions is specific to monitoring and control instruments for medical devices. The consultation period started on 30 November 2021 and will last for a period of 10 weeks, finishing on 8 February 2022. When submitting stakeholder contributions, it should clearly state if the exemption requests are justified or if there is no explanation. Your contribution must be supported by relevant technical and scientific evidence presented as part of the submission. The confidential information submitted during the consultation will be posted on the CIRCABC (Communication and Information Resource Centre for Administrations, Businesses and Citizens) website. Stakeholders will be given the opportunity to exchange further information after the consultation. Following the consultation period, the exchange of information or need for technical discussion will be identified. Consultations will be conducted with the following groups: EEE industry EEE industry federations Consultancies Research institutions & universities NGOs Public administrations To stay abreast of regulatory updates around material compliance, ask for a no-cost Compliance Gap Analysis with one of our global compliance specialists today!
Do your products comply with the ROHS 2 delegated directive 2015/863?
Any business that sells electrical/electronic products, sub-assemblies or components directly to EU countries, or sells to resellers, distributors or integrators that in turn sell products to EU countries, are required to comply with EU RoHS Directive The European Commission published the first RoHS Directive 2002/95/EC on the restriction of the use of six hazardous substances in electrical and electronic equipment (EEE) is referred to as RoHS 1 and the recast Directive 2011/65/EU is referred to as RoHS 2. The Commission published the RoHS 2 delegated directive 2015/863 on 04 June 2015 by adding 4 phthalates to the list of restricted substances in Annex II to Directive 2011/65/EU (RoHS 2). All EEE manufacturers should comply with the RoHS recast requirements by 22 July 2019, except for medical devices and monitoring and control instrument manufacturers, for whom the compliance deadline is 22 July 2021. Major features of the RoHS 2 recast are: Addition of low molecular weight Orthophthalates: DEHP, BBP, DBP, DIBP restricted at 1,000 ppm in homogenous materials The restriction of phthalates DEHP, BBP, DBP and DIBP shall not apply to cables or spare parts for the repair, reuse, updating of functionalities or upgrading of capacity of EEE placed on the market before 22 July 2019 The restriction of phthalates DEHP, BBP and DBP shall not apply to toys which are already subject to the restriction of DEHP, BBP and DBP through entry 51 of Annex XVII to Regulation (EC) No 1907/2006 (REACH). Manufacturers must ensure that EEE are CE marked and must prepare a declaration of conformity confirming that they have complied with the regulations. The general principles of CE marking are outlined in Regulation 768/2008/EC. Below are the broad categories of EEE that are covered under the RoHS 2 recast RoHS 2 is applicable to these categories Categories exempted from RoHS 2 Large household appliances Small household appliances IT and telecommunications equipment Consumer equipment Lighting equipment Electrical and electronic tools Toys, leisure and sports equipment Automatic dispensers Non-industrial monitoring and control instruments Medical devices and monitoring and control instruments from July 2021 In vitro medical devices, from July 2021 Industrial monitoring and control instruments, from July 2021. Equipment built for military purposes and needed for national security. Equipment designed for space travel. Transport for people or goods. Active medical implants. Photovoltaic panels (for public, commercial, industrial or residential use). Equipment specifically designed for research and development (for professional use). Non-road mobile machinery for professional use that has an onboard motor. Large-scale stationary industrial tools. Large-scale fixed installations. Equipment specifically designed to be part of another type of equipment that is exempted. (EEE is defined as any equipment with a voltage rating not exceeding 1,000V for AC and 1,500V for DC that requires electric currents or electromagnetic fields to work, or equipment used for the generation, transfer and measurement of electric currents and fields. EEE can be a component or assembly used in a finished product. Cables and spare parts for repairing, reusing, updating or upgrading a product are all EEE.) Do you want to learn more about how to comply with the RoHS 2 recast before the deadline? Talk to the compliance experts at ComplianceXL.