EU RoHS
February 9, 2026 | Written by GreenSoft Technology, Inc.
EU RoHS Exemption Updates
Update on Recent Changes to EU RoHS Annex III Exemption Renewals and Expirations
In November, the European Commission published renewal decisions for several EU RoHS Annex III exemptions in the Official Journal of the European Union. These exemptions, including 7(a), 7(c)-I, 6(a), 6(b), and 6(c), play a vital role in the electronics manufacturing industry.
These new exemption updates came into force on December 11, 2025, with an applicability date of July 1, 2026. However, many of the expiry dates defined in these decisions have already been invalidated by new renewal requests submitted by stakeholders between Dec. 11, 2025, and Dec. 16, 2025. Those dates are no longer valid because exemptions with an active renewal request remain valid until the EU Commission issues a decision, which will either assign a new expiry date or provide a 12–18‑month transition period before phase‑out.
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
EU RoHS Exemption Renewals Reference Guide
This quick reference guide provides a summary of the updated exemptions, their associated expiry dates, and (where applicable) renewal deadlines.
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Summary of the Latest Exemption Updates
The updates are complex, and producers are encouraged to review potential impacts to their products. Some exemptions have been renewed, some have been renewed with varying expiry dates under new application-specific exemptions, and some have not been renewed at all. Additionally, many of the expiry dates defined in these decisions have already been invalidated by new renewal requests. Below is a summary of the changes:
Exemption 7(a): This exemption was to 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. However, 7(a) is now under a new renewal request submitted December 12, 2025. Additionally, exemptions 7(a)-I through 7(a)-VII are impacted by and included as part of the 7(a) renewal request.
Exemption 7(c)-I: This exemption was to 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. However, 7(c)-I is now under a new renewal request submitted December 12, 2025. Additionally, exemptions 7(c)-V and 7(c)-VI are impacted by and included as part of the 7(c)-I renewal request.
Exemption 7(c)-II: This exemption was set to expire on December 31, 2027, but is also impacted by and included as part of the 7(c)-I renewal request.
Updated on February 20, 2026:
Exemption 6(a): This exemption will not be renewed and now applies to all categories until it ceases to be in force on December 11, 2026. (Prior to this update, this exemption only applied to product categories 8,9 and 11.) However, Exemption 6(a) has been broken up into two more narrowly applied exemptions – 6(a)-I and 6(a)-II. Both 6(a)-I and 6(a)-II were set to expire on June 30, 2027, but are now under a new renewal request submitted December 16, 2025.
Exemption 6(b): This exemption applied to categories 8, 9 and 11 prior to this update, will not be renewed until it ceases to be in force on June 11, 2027. The delegated directive does not clearly state if exemption 6(b) will continue to apply only to categories 8,9 and 11, or if it will apply to all categories until it’s new expiry. Manufacturers of all categories should plan to transition to exemptions 6(b)-II, or 6(b)-III, which have new renewal requests in place as noted below.
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]. Exemption 6(b)-I will remain in force for product categories 9 (industrial monitoring and control equipment) and 11 until June 30, 2027. Exemption 6(b)-II will remain in force for product category 9 (industrial monitoring and control equipment) until June 30, 2027. Exemption 6(b)-II was set to expire for product category 11 on June 30, 2027, but is now under a new renewal request submitted on December 17, 2025.
Additionally, a new Exemption 6(b)-III is provided which applies to product categories 1-8, 9 (other than industrial monitoring and control equipment), and 10. Exemption 6(b)-III was set to expire June 30, 2027, but is now under new renewal requests submitted on December 11 and December 15, 2025.
Exemption 6(c): This exemption was set to expire June 30, 2027, but is now under a new renewal request submitted on December 12, 2025.
Detailed EU RoHS Exemption Updates
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 (Requested for renewal) |
| 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 (impacted by 7(a) Request) |
| 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 (impacted by 7(a) Request) |
| 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 (impacted by 7(a) Request) |
| 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 (impacted by 7(a) Request) |
| 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 (impacted by 7(a) Request) |
| 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 (impacted by 7(a) Request) |
| 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 (impacted by 7(a) Request) |
| 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 (Requested for renewal) |
| 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 (impacted by 7(c)-I Request) |
| 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 (impacted by 7(c)-I Request) |
| 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 (impacted by 7(c)-I Request) |
| 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 All |
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 (Requested for renewal) |
| 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 (Requested for renewal) |
| 6(b) | Lead as an alloying element in aluminium containing up to 0,4 % lead by weight | Not Renewed | 8, 9, and 111 | 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 | 9 (Industrial): June 30, 2027 11: June 30, 2027, (Requested for renewal) | ||
| 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 (Requested for renewal) |
| 6(c) | Copper alloy containing up to 4 % lead by weight* | Renewed | All | June 30, 2027 (Requested for renewal) |
*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.)
1. Exemption 6(b) was applicable only to product categories 8,9 and 11 prior to the publication of Commission Delegated Directive (EU) 2025/2364. While (EU) 2025/2364 provides a new expiry date for exemption 6(b), it makes no reference of changes to applicable product categories and provides no indication of renewed coverage for categories 1-7 and 10. (Categories 1-7 and 10 were removed from 6(b) in May 2018 and moved to 6(b)-I and 6(b)-II.) However, the RoHS-2 Exemption Validation and Rolling Plan (Version 19-12-2025) shows 6(b) as now being applicable to all categories. GreenSoft is using the most conservative interpretation that coverage is not expanded to categories 1-7 and 10.
Frequently Asked Questions (FAQ):
How the Latest EU RoHS Exemption Updates Affect Electronics Manufacturers & How GreenSoft Can Help
How do I know whether these exemption changes impact my products?
If your products rely on lead‑based solders, leaded ceramics, or metal alloys containing lead, there is a strong chance you are affected. Exemptions are still in force when under review for renewals, which means expiry dates published in the EU’s Official Journal are no longer valid for exemptions under review until the EU Commission issues new decisions. If your components rely on any of these exemptions, your compliance status may change once new decisions are published.
How GreenSoft helps:
GreenData Manager (GDM) software allows you to review your entire BOM and identify parts affected by expiring, so that you’re alerted to risk areas before an EU RoHS exemption expiration disrupts production.
What does it mean that many expiration dates are “invalidated” due to renewal requests?
Under EU RoHS rules, once stakeholders submit a timely renewal request, the current exemption remains valid until the EU Commission makes a new decision—even if the previously published expiry date has already passed. This applies to major exemptions such as 7(a), 7(c)-I, 6(a)-I, 6(a)-II, 6(b)-II (cat. 11), 6(b)-III, and 6(c), all of which received renewal requests between Dec. 11–17, 2025.
How GreenSoft helps:
GreenSoft continuously tracks exemption statuses and keeps you informed when an exemption enters renewal, expires, or is replaced.
What should I do if my products currently rely on exemptions that were not renewed?
Certain exemptions will not be renewed, including:
- 6(a) now for all categories (expires Dec 11, 2026)
- 6(b) for categories 8, 9, and 11 (expires June 11, 2027)
- (Note: The RoHS-2 EU Exemption Validation and Rolling plan shows 6(b) will now apply to all categories, however, this is not expressly confirmed in the delegated regulation, and the rolling plan is provided as a reference document only.)
- 6(b)-I and 6(b)-II for categories 1–7 and 10 (expire Dec 11, 2026 or June 11, 2027 depending on sub-entry)
If your parts depend on any of these exemptions, you may need to:
- Check to determine if another exemption may apply. For example, it may be possible to demonstrate compliance using exemption 6(a)-I or 6(a)-II instead of exemption 6(a) for certain applications of steel alloys containing lead.
- Begin transitioning to RoHS compliant alternatives
- Requalify materials/components
- Communicate with suppliers to understand their plans for redesign
How GreenSoft helps:
GreenSoft maintains a continuously updated list of verified replacement suppliers across 19 component categories, each offering EU RoHS‑compliant components. If one of your products relies on an expiring exemption, GreenSoft can recommend suitable alternative suppliers from this vetted list, helping shorten redesign cycles, reduce sourcing uncertainty, and prevent production delays.
How can I keep up with new exemption subcategories (like 7(a)-I through 7(a)-VII or 6(a)-I and 6(a)-II)?
The updates introduce many new, more narrow exemption entries, each with its own technical requirements and (original) expiration timeline. These include:
- 7(a)-I to 7(a)-VII for lead in specific high‑temperature solder applications
- 7(c)-V and 7(c)-VI for lead in specialized ceramics and glass uses
- 6(a)-I / 6(a)-II and 6(b)-III for lead in specific metal-alloy use cases
However—most of these new sub‑entries are now tied to renewal requests, causing their recently published expiry dates (e.g., Dec 31, 2027 or June 30, 2027) to be invalid until the Commission rules on the new requests.
How GreenSoft helps:
To support companies navigating these rapidly evolving EU RoHS exemption changes, GreenSoft is offering a free educational webinar where you can learn the details, understand potential product impacts, and participate in a live Q&A session to get your specific questions answered. You can register here: https://www.greensofttech.com/resources/events/webinar-registration-navigating-the-latest-eu-rohs-exemption-updates/
What’s the most efficient way to ensure ongoing RoHS compliance as these exemption updates continue to change?
With so many exemptions now in renewal and multiple sub‑entries introduced, manual tracking is risky and time-consuming. The keys to staying compliant are:
- Maintaining accurate, up‑to‑date supplier data – Be in constant communication with suppliers!
- Continuously monitoring exemption renewal status updates, industry renewal request submissions, legislative changes, and supplier compliance trends.
- Having a centralized system to track data validity and risk
How GreenSoft helps:
GreenSoft helps you stay compliance through:
- Direct Supplier Engagement: Our data team contacts your suppliers directly to collect updated chemical data on your parts and materials.
- 99.9% Data Accuracy: We perform manual and automated validation to ensure the data you receive is accurate and complete.
- GreenData Manager (GDM): Manage your compliance data in a centralized database that is updated as regulations change.
- Continuous monitoring of EU RoHS regulatory changes: ensures your products stay compliant throughout constant regulatory updates.
Learn about how our data solutions and GreenData Manager software can support your compliance efforts year-round. Contact us to get started with a personalized demo.