EU RoHS
November 26, 2025 | Written by GreenSoft Technology, Inc.
EU RoHS Exemption Renewals Officially Published
Renewal Decisions for critical EU RoHS exemptions officially published
In September, the European Commission adopted several renewal decisions for several EU RoHS Annex III exemptions, including many exemptions that are heavily applied and essential for electronics manufacturers such as 7(a), 7(c)-I, 7(c)-II, 6(a), 6(b), and 6(c).
The adoption of these exemptions was officially published in the Official Journal of the European Union on November 21, and therefor enter into force on the twentieth day following the publication, which is December 11, 2025.
The official publications can be found in the links below:
- 6(a), 6(b) and 6(c) exemption series: https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX:32025L2364
- 7(a) exemption series: https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX:32025L1802
- 7(c) exemption series: https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX:32025L2363
Summary of 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, 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, 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.
Exemption 6(a): This exemption will not be renewed for categories 8, 9, and 11, and will cease to be in force on December 11, 2026. (For categories 1-7 and 10 this exemption has already expired.) However, Exemption 6(a) 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.
Exemption 6(b): This exemption will not be renewed for categories 8, 9, and 11, and will cease to be in force on June 11, 2027. (For categories 1-7 and 10 this exemption has already expired.)
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 on December 11, 2026 [6(b)-I] or June 11, 2027 [6(b)-II]. However, these exemptions will remain in force for product categories 9 (industrial monitoring and control equipment) and 11 until June 30, 2027.
Additionally, a new Exemption 6(b)-III is provided which will expire June 30, 2027 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.
The list of updated exemptions, their updated expiry dates, and links to the official delegated directives can be found in the table below:
|
Exemption |
Description |
Status |
Product Category |
Expiry Date |
|
7(a) |
Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead) |
Renewed |
All |
June 30, 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 x 0.3 mm |
New |
All |
Dec 31, 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 >35W/(m*K), - the electrical conductivity of the cured/sintered die attach material is >4.7MS/m , - solidus melting temperature is higher than 260°C |
New |
All |
Dec 31, 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 sealings |
New |
All |
Dec 31, 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 grid-array (BGA) 2. in high temperature plastic overmouldings (> 220 °C) |
New |
All |
Dec 31, 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 |
New |
All |
Dec 31, 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 |
New |
All |
Dec 31, 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 |
New |
All |
Dec 31, 2027 |
|
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 |
Renewed |
All |
June 30, 2027 |
|
7(c)-II |
Lead in dielectric ceramic in capacitors for a rated voltage of 125 V AC or 250 V DC or higher excluding applications covered by point 7(c)-I or 7(c)-IV |
Renewed as modified |
All |
Dec 31, 2027 |
|
7(c)-V |
Electrical and electronic components containing lead in a glass or glass matrix compound that fulfils any of the following functions: 1) for protection and electrical insulation in glass beads of high-voltage diodes and glass layers for wafers on the basis of a lead-zinc-borate or a lead-silica-borate glass body; 2) for hermetic sealing between ceramic, metal and/or glass parts; 3) for bonding purposes in a process parameter window for < 500 °C combined with a viscosity of 1013.3 dPas (‘glass-transition temperature’); 4) for use as a resistive material such as ink, with a resistivity range from 1 ohm/square to 1 megohm/square, excluding trimmer potentiometers; 5) for use in chemically modified glass surfaces for microchannel plates (MCPs), channel electron multipliers (CEMs) and resistive glass products (RGPs). |
New |
All |
Dec 31, 2027 |
|
7(c)-VI |
Electrical and electronic components containing lead in a ceramic that fulfils any of the following functions (excluding items covered by points 7(c)-II, 7(c)-III and 7(c)-IV, as well as point 14 of Annex IV) 1) for use in piezoelectric lead zirconium titanate (PZT) ceramics; 2) for providing ceramics with a positive temperature coefficient (PTC).’ |
New |
All |
Dec 31, 2027 |
|
6(a) |
Lead as an alloying element in steel for machining purposes and in galvanised steel containing up to 0,35 % lead by weight |
Not Renewed |
8, 9, and 11 |
Dec 11, 2026 |
|
6(a)-I |
Lead as an alloying element in steel for machining purposes containing up to 0,35 % lead by weight* |
Renewed as modified |
All |
June 30, 2027 |
|
6(a)-II |
Lead as an alloying element in batch hot-dip galvanised steel components containing up to 0,2% lead by weight* |
New |
All |
June 30, 2027 |
|
6(b) |
Lead as an alloying element in aluminium containing up to 0,4 % lead by weight |
Not Renewed |
8, 9, and 11 |
June 11, 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 aluminum scrap recycling* |
Not Renewed |
1-7 and 10 |
Dec 11, 2026 |
|
Renewed |
9 (industrial) and 11 |
June 30, 2027 |
||
|
6(b)-II |
Lead as an alloying element in aluminium for machining purposes with a lead content up to 0,4 % by weight* |
Not Renewed |
1-7 and 10 |
June 11, 2027 |
|
Renewed |
9 (industrial) and 11 |
June 30, 2027 |
||
|
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* |
New |
1-8, 10, and 9 (other than industrial) |
June 30, 2027 |
|
6(c) |
Copper alloy containing up to 4 % lead by weight* |
Renewed |
All |
June 30, 2027 |
*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.)
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.
Stakeholders who intend to submit requests for any exemptions designated to expire in June 2027 should be finalizing their dossier(s) for exemption renewal soon, as they will have only a few weeks to submit their requests.
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.