RoHS Exemptions for Groups 6 and 7 of Annex III: Where do we stand?
European Commission adopts delegated directives renewing exemptions for lead in metals and electronic components
01 Oct 2025On 17 February, a draft notification regarding the renewal of specific RoHS exemptions for lead was submitted to the WTO.
On 8 September, the European Commission adopted the delegated directives, introducing some changes compared to the preliminary versions previously mentioned.
The table below lists the exemptions whose expiry dates have been modified compared to the drafts. All other expiry dates currently remain unchanged.
|
Annex III RoHS II Exemption |
Expiry date in draft delegated directive |
Expiry date in adopted delegated directive |
|
6(a)-I |
Lead as an alloying element in steel for machining purposes containing up to 0.35% lead by weight*. |
31/12/2026 |
|
6(a)-II |
Lead as an alloying element in batch hot-dip galvanised steel components containing up to 0.2% lead by weight. |
31/12/2026 |
|
6(b) |
Lead as an alloying element in aluminium containing up to 0.4% lead by weight. |
12 months after entry into force |
|
6(b)-I |
Lead as an alloying element in aluminium containing up to 0.4% lead by weight, provided it comes from recycled aluminium scrap containing lead*. |
12 months after entry into force for categories 1–7 and 10; 31/12/2026 for category 9 (industrial monitoring and control instruments) and category 11. |
|
6(b)-II |
Lead as an alloying element in aluminium containing up to 0.4% lead by weight*. |
18 months after entry into force for categories 1–7 and 10; 31/12/2026 for category 9 (IMCI) and category 11. |
|
6(b)-III |
Lead as an alloying element in aluminium casting alloys containing up to 0.3% lead by weight, provided it comes from recycled aluminium scrap containing lead*. |
31/12/2026 for categories 1–8, 9 (IMCI), and 10. |
|
6(c) |
Copper alloys containing up to 4% lead by weight*. |
31/12/2026 |
|
7(a) |
Lead in high melting temperature type solders (e.g. lead-based alloys containing 85% by weight or more of lead). |
31/12/2026 |
|
7(c)-I |
Electrical and electronic components containing lead in glass or ceramics other than dielectric ceramics in capacitors (e.g. piezoelectric devices), or in a glass or ceramic matrix. |
31/12/2026 |
As delegated directives, the approval process is expected to be relatively straightforward, without requiring formal votes by the European Parliament and the Council.
Unless objections are raised, it is likely that the directives could be published as early as November.
This development highlights the importance of collaboration along the supply chain. While some exemption deadlines have been extended, it is advisable to promptly engage in dialogue with suppliers to gather information on potential alternatives. This is particularly relevant where purchased or marketed products contain lead exceeding the thresholds set in Annex II of the RoHS II Directive, making it necessary to rely on one of the exemptions listed above.