EU RoHS Lead Exemption Renewals: Risks and Readiness for Manufacturers
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: Major Annex III Lead Exemptions to Monitor 1. Lead in High-Temperature Solders Exemption 7(a) 2. Lead in Glass of Electronic Components Exemption 7(c)-I 3. Lead in Ceramic Parts (e.g., Piezoelectric Devices) Exemptions 7(c)-I & 7(c)-IV 4. Lead in Dielectric Ceramic in Capacitors Exemption 7(c)-II 5. Lead in Solder for Servers, Storage, and Networking Equipment Exemptions 7(a), 7(c)-I (application-dependent) 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) 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: 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: 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.