EU RoHS

September 19, 2025 | Written by GreenSoft Technology, Inc.

EU RoHS Exemption Renewals Adopted

Renewal Decisions for critical EU RoHS exemptions officially adopted

The European Commission has adopted several renewal decisions for several EU RoHS Annex III exemptions, including critical exemptions such as 7(a), 7(c)-I, 7(c)-II, 6(a), 6(b), and 6(c).

These EU RoHS Annex III exemptions, many of which are heavily applied and essential for electronics manufacturers, have been without effective expiry dates since requests for renewal were submitted as far back as November of 2019.

These decisions have been long-awaited by industry, and producers are encouraged to review potential impacts to their products.

As noted in our January 29 blog post, draft renewal decisions were published by the EU Commission for these critical exemptions in January 2025. In those draft decisions, the EU authorities had indicated specific expiry dates for those exemptions. Because of delays in adopting those draft decisions, the final adopted versions have some changes to expiry dates which vary from the initial published drafts.

Summary of Draft Exemption Updates

The updates are complex, as some exemptions have been designated to be renewed, some designated as renewed with varying expiry dates under new application-specific exemptions, and some designated not to be renewed at all. Below is a summary of the changes:

Exemption 7(a): This exemption will remain in force in its current form until June 30, 2027 (extended from the initially proposed date of December 31, 2026), with specific more narrowly defined applications being additionally extended until December 31, 2027 by new exemptions 7(a)-I through 7(a)-VII.

Exemption 7(c)-I: This exemption will remain in force in its current form until June 30, 2027 (extended from the initially proposed date of December 31, 2026), with specific more narrowly defined applications being additionally extended until December 31, 2027 by new exemptions 7(c)-V and 7(c)-VI.

Exemption 7(c)-II: This exemption will remain in force until December 31, 2027 (no change from initial proposed date.)

Exemption 6(a): This exemption will not be renewed and will cease to be in force 12 months after the final delegated directive comes into force. However, Exemption 6(a)-I will be broken up into two exemptions – 6(a)-I and 6(a)-II, both of which will be in force until June 30, 2027 (extended from the initially proposed date of December 31, 2026).

Exemption 6(b): This exemption will not be renewed and will cease to be in force 18 months (extended from the initially proposed 12-month period) after the final delegated directive comes into force.

Exemptions 6(b)-I and 6(b)-II: These exemptions will not be renewed for product categories 1-7 and 10 and will cease to be in force 12 months [6(b)-I] or 18 months [6(b)-II] after the final delegated directive comes into force. However, these exemptions will remain in force for product categories 9 (industrial monitoring and control equipment) and 11 until June 30, 2027 (extended from the initially proposed date of December 31, 2026).

Additionally, a new Exemption 6(b)-III is provided which will expire June 30, 2027 (extended from the initially proposed date of December 31, 2026) and applies to product categories 1-8, 9 (other than industrial monitoring and control equipment), and 10.

Exemption 6(c): This exemption will remain in force until June 30, 2027 (extended from the initially proposed date of December 31, 2026).

The list of updated exemptions, their updated expiry dates, and links to the official draft delegated directives can be found in the table below:

*The exemption shall not cover EEE for supply to the general public where the EEE or accessible part thereof may, during normal or foreseeable conditions of use, be placed in the mouth by children. However, the exemption shall apply where the following can be both demonstrated:

— the rate of lead release from such an EEE or any accessible part, whether coated or uncoated, does not exceed 0,05 μg/cm2 per hour (equivalent to 0,05 μg/g/h),

— for coated articles, that the coating is sufficient to ensure that this release rate is not exceeded for a period of at least two years of normal or reasonably foreseeable conditions of use of the EEE.

(For the purpose of this footnote, it is considered that an EEE or accessible part of an EEE may be placed in the mouth by children if it is smaller than 5 cm in one dimension or has a detachable or protruding part of that size.)

What’s Next?

According to the EU Commission’s website, the newly adopted delegated directives will be subject to a two-month scrutiny period of the European Parliament and the Council (an extension of the scrutiny period on request is possible). After this scrutiny period, in case of no objections from the co-legislators, the Delegated Directive will be published in the Official Journal. The updates will come into force 20 days after publication. With this in mind, these changes are expected to be published by the end of 2025.

Can these exemptions be subject to new renewal requests?

As noted in Article 5(5) of EU RoHS Directive 2011/65/EU, an application for exemption renewal cannot be made any later than 18 months before the exemption expires. This means any renewal requests for exemptions which expire June 30, 2027 must be submitted by December 30, 2025.

Considering the publication schedule noted above, and that new requests cannot be submitted until these delegated directives are in force, time is limited. Stakeholders who intend to submit requests for any exemptions designated to expire in June 2027 should start working on their dossier(s) for exemption renewal now.

Exemptions which expire on December 31, 2027, have a little more time; those submissions will need to be made by June 30, 2026. For exemptions that have not been renewed and expire 12 or 18 months after the delegated directives come into force, applications for renewal are not possible.

GreenSoft can help with EU RoHS compliance

With the European Commission officially adopting renewal decisions for critical EU RoHS exemptions, electronics manufacturers now have clarity on the updated expiry dates and conditions for these exemptions.  Companies should now promptly assess the impact on their products and compliance strategies based on the renewal actions outlined above.

EU RoHS compliance is mandatory for affected companies that manufacture or distribute products in the European market. Failure to comply with EU RoHS can result in loss of market access, supply chain disruptions, and other serious consequences for manufacturers and distributors.

GreenSoft Technology provides personalized Data Services and GreenData Manager software to help electronics manufacturers with EU RoHS compliance. We’ll collect data on the chemicals contained in your products so that you can ensure you’re complying with the EU RoHS Directive.

Learn more about our environmental compliance Data Services or contact us today to get started.