RoHS

Update of RoHS Annex III lead exemptions: three new Delegated Directives published

Three Commission Delegated Directives (EU) 2025/2364, (EU) 2025/1802, (EU) 2025/2363 published, renewing Annex III RoHS exemptions of series 6a, 6b, 6c, 7a and 7c for lead

17 Dec 2025

On 21 November 2025, the European Commission published three Delegated Directives that formalize the update of the Annex III exemption series 6a, 6b, 6c, 7a and 7c of Directive 2011/65/EU (RoHS). As anticipated, these Directives confirm the contents and expiry dates already reported in the Directives adopted by the Commission in September, which we discussed here.

Below are the new exemptions and their respective expiry dates:

  • Commission Delegated Directive (EU) 2025/2364 - amendment of the series 6 exemptions (6a, 6b and 6c) concerning lead as an alloying element in steel, aluminium and copper:

 

Exemption

Expiry

6 a)

Lead as an alloying element in steel for machining purposes and in galvanised steel containing up to 0,35 % lead by weight

11 December 2026

6 a)-I

Lead as an alloying element in steel for machining purposes containing up to 0,35 % lead by weight (*)

30 June 2027 for all categories

6 a)-II

Lead as an alloying element in batch hot-dip galvanised steel components containing up to 0,2 % lead by weight (*)

30 June 2027 for all categories

6 b)

Lead as an alloying element in aluminium containing up to 0,4 % lead by weight

11 June 2027

6 b)-I

Lead as an alloying element in aluminium containing up to 0,4 % lead by weight, provided it stems from lead-bearing aluminium scrap recycling (*)

11 December 2026 for categories 1-7, 10
30 June 2027 for categories 9 industrial monitoring and control instruments, and 11.

6 b)-II

Lead as an alloying element in aluminium for machining purposes with a lead content up to 0,4 % by weight (*)

11 June 2027 for categories 1-7, 10.
30 June 2027 for categories 9 industrial monitoring and control instruments and 11(*).

6 b)-III

Lead as an alloying element in aluminium casting alloys containing up to 0,3 % lead by weight provided it stems from lead-bearing aluminium scrap recycling (*)

30 June 2027 for categories 1-8, 9 other than industrial monitoring and control instruments, and 10.

6 c)

Copper alloy containing up to 4 % lead by weight (*)

30 June 2027.

 

  • Commission Delegated Directive (EU) 2025/1802 - amends the series 7a exemptions concerning lead in high melting temperature solders:

7 a)

Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead)

Applies to all categories (except applications covered by point 24 of this Annex) and expires on 30 June 2027

7 a)-I

Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead) for internal interconnections for attaching die, or other components along with a die in semiconductor assembly with steady state or transient/impulse currents of 0,1 A or greater or blocking voltages beyond 10 V, or die edge sizes larger than 0,3 mm × 0,3 mm

Applies to all categories (except applications covered by point 24 of this Annex) and expires on 31 December 2027

7 a)-II

Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead) for integral (meaning internal and external) connections of die attach in electrical and electronic components, if all the following conditions are met:

— the thermal conductivity of the cured/sintered die-attach material is > 35 W/(m × K),

— the electrical conductivity of the cured/sintered die-attach material is > 4,7 MS/m,

— solidus melting temperature is higher than 260 °C

Applies to all categories (except applications covered by point 24 of this Annex) and expires on 31 December 2027

7 a)-III

Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead) in first level solder joints (internal or integral connections – meaning internal and external) for manufacturing components so that subsequent mounting of electronic components onto subassemblies (i.e. modules, sub-circuit boards, substrates, or point-to-point soldering) with a secondary solder does not reflow the first level solder. This sub-entry excludes die attach applications and hermetic sealing

Applies to all categories (except applications covered by point 24 of this Annex) and expires on 31 December 2027

7 a)-IV

Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead) in second level solder joints for the attachment of components to printed circuit board or lead frames:

(1) in solder balls for the attachment of ceramic ball-gridarray (BGA);

(2) in high temperature plastic overmouldings (> 220 °C)

Applies to all categories (except applications covered by point 24 of this Annex) and expires on 31 December 2027

7 a)-V

Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead) as a hermetic sealing material between:

(1) a ceramic package or plug and a metal case;

(2) component terminations and an internal sub-part

Applies to all categories (except applications covered by point 24 of this Annex) and expires on 31 December 2027

7 a)-VI

Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead) for establishing electrical connections between lamp components in incandescent reflector lamps for infrared heating, high intensity discharge lamps, or oven lamps

Applies to all categories (except applications covered by point 24 of this Annex) and expires on 31 December 2027

7 a)-VII

Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead) for audio transducers where the peak operating temperature exceeds 200 °C

Applies to all categories (except applications covered by point 24 of this Annex) and expires on 31 December 2027

 

  • Commission Delegated Directive (EU) 2025/2363 amends the exemption concerning lead in glass or ceramic components by updating entries 7c-I and 7c-II and introducing the new exemptions 7(c)-V and 7(c)-VI:

 

7 c)-I

Electrical and electronic components containing lead in a glass or ceramic other than dielectric ceramic in capacitors, e.g. piezoelectronic devices, or in a glass or ceramic matrix compound

Applies to all categories and expires on 30 June 2027.

7 c)-II

Lead in dielectric ceramic in capacitors for a rated voltage of 125 V AC or 250 V DC or higher

Applies to all categories (except applications covered by point 7(c)-I or 7(c)-IV) and expires on 31 December 2027.



Member States have until 30 June 2026 to transpose the Directives in question, which will apply from 1 July 2026.

Although some deadlines concerning the applicability of the exemptions have been extended, we consider it advisable to maintain an active dialogue with suppliers to gather information on possible alternatives, should the purchased and marketed products contain lead in amounts exceeding the limits set out in Annex II of the RoHS II Directive. In such cases, relying on one of the available exemptions would therefore be necessary.