RoHS: lead exemptions restructured from 1 July 2026

Author Hugues Orgitello Last updated 22 August 2026 ~7 min read

News · Regulatory evolution

Three Commission Delegated Directives of 8 September 2025, (EU) 2025/1802, (EU) 2025/2363 and (EU) 2025/2364, published in the Official Journal on 21 November 2025 and in force since 11 December 2025, redraw the lead exemptions in Annex III to the RoHS Directive 2011/65/EU. Article 2(1) of each required Member States to transpose by 30 June 2026 and to apply the measures from 1 July 2026. Entries 6(a), 6(b), 6(c), 7(a) and 7(c) are broken into narrower sub-entries, each carrying a hard expiry date in 2026 or 2027.

In short:

The three delegated directives of 8 September 2025 had to be transposed by 30 June 2026 and applied in national law from 1 July 2026.
Exemption 7(a), high melting temperature type solders, expires on 30 June 2027 and gives way to seven sub-entries expiring on 31 December 2027.
Lead in steel, aluminium and copper now carries separate deadlines: 11 December 2026, 11 June 2027 or 30 June 2027.
Cadmium entry 39(a) expired for all categories on 21 November 2025; new entry 39(b) runs to 31 December 2027.
There is no merger with the ESPR: Directive (EU) 2025/2456 moves exemption handling to ECHA on 13 August 2027.

High melting temperature solders: 7(a) becomes seven entries

Recital 9 of Delegated Directive (EU) 2025/1802 states the reasoning plainly: exemption 7(a) is widely used, and sometimes without any technical need for it. Recital 8 explains why it survives anyway: lead-free solutions will not be available in the next three years, or will be available only with insufficient reliability for all the relevant applications.

Entry 7(a) itself, lead-based alloys containing 85 % by weight or more lead, expires on 30 June 2027; the seven new sub-entries expire on 31 December 2027. All apply to every category except applications covered by point 24 of the Annex.

Sub-entry	Technical scope
7(a)-I	Internal interconnections attaching a die in semiconductor assembly: currents of 0,1 A or more, blocking voltages beyond 10 V, or die edges larger than 0,3 mm x 0,3 mm
7(a)-II	Integral die-attach connections where the cured or sintered material exceeds 35 W/(m x K) thermal conductivity, 4,7 MS/m electrical conductivity and a 260 °C solidus
7(a)-III	First level solder joints, excluding die attach and hermetic sealings
7(a)-IV	Second level joints attaching components to printed circuit board or lead frames: ceramic BGA solder balls, high temperature plastic overmouldings beyond 220 °C
7(a)-V	Hermetic sealing between a ceramic package or plug and a metal case, or between component terminations and an internal sub-part
7(a)-VI	Connections between lamp components: incandescent reflector lamps for infrared heating, high intensity discharge lamps, oven lamps
7(a)-VII	Audio transducers whose peak operating temperature exceeds 200 °C

Glass, ceramic and dielectrics: entry 7(c)

Entry	Subject	Scope	Expiry
7(c)-I	Lead in a glass or ceramic other than dielectric ceramic in capacitors, or in a glass or ceramic matrix compound	All categories	30 June 2027
7(c)-II	Lead in dielectric ceramic in capacitors rated 125 V AC or 250 V DC or higher	All, except 7(c)-I and 7(c)-IV	31 December 2027
7(c)-V (new)	Lead in a glass or glass matrix compound, five listed functions: glass beads of high-voltage diodes, hermetic sealing, bonding below 500 °C at 1 013,3 dPas, resistive material from 1 ohm/square to 100 megohm/square, microchannel plate glass	All categories	31 December 2027
7(c)-VI (new)	Lead in piezoelectric PZT ceramics, or giving ceramics a positive temperature coefficient	All, except 7(c)-II to 7(c)-IV and point 14 of Annex IV	31 December 2027

Steel, aluminium, copper: deadlines that vary by category

Entry	Subject	Categories	Expiry
6(a)	Lead in steel for machining and in galvanised steel, up to 0,35 %	All	11 December 2026
6(a)-I	Lead in steel for machining, up to 0,35 %	All	30 June 2027
6(a)-II (new)	Lead in batch hot-dip galvanised steel components, up to 0,2 %	All	30 June 2027
6(b)	Lead in aluminium, up to 0,4 %	All	11 June 2027
6(b)-I	Same, where the lead stems from lead-bearing aluminium scrap recycling	1 to 7 and 10, then 9 industrial monitoring and control and 11	11 December 2026, then 30 June 2027
6(b)-II	Lead in aluminium for machining, up to 0,4 %	1 to 7 and 10, then 9 industrial monitoring and control and 11	11 June 2027, then 30 June 2027
6(b)-III (new)	Aluminium casting alloys up to 0,3 %, from lead-bearing scrap recycling	1 to 8, 9 other than industrial monitoring and control, 10	30 June 2027
6(c)	Copper alloy containing up to 4 % lead	All	30 June 2027

Recital 14 of Delegated Directive (EU) 2025/2364 signals what comes next: intentionally added lead in aluminium for machining purposes is no longer needed in electrical and electronic equipment, reliable substitutes exist, and the eighteen-month transition of Article 5(6) is there to let market participants adapt.

A footnote attached to entries 6(a)-I, 6(a)-II, 6(b)-I, 6(b)-II, 6(b)-III and 6(c) is easy to miss. It removes the exemption for equipment supplied to the general public where the equipment, or an accessible part of it, may be placed in the mouth by children, which is presumed where that equipment or part is smaller than 5 cm in one dimension or has a detachable or protruding part of that size, unless two conditions are met: a lead release rate, coated or uncoated, of no more than 0,05 microgram/cm2 per hour, and for coated articles a coating holding that rate for at least two years. Recital 17 ties the wording to point 7 of entry 63 in Annex XVII to Regulation (EC) No 1907/2006.

Cadmium and recovered PVC: two acts already in force

Delegated Directive (EU) 2024/1416 of 13 March 2024 closed entry 39(a), cadmium selenide in downshifting quantum dots for display lighting, on 21 November 2025 for all categories. It inserted entry 39(b), cadmium in downshifting quantum dots deposited directly on LED semiconductor chips for display and projection, capped at 1 mg per device, expiring on 31 December 2027.

Delegated Directive (EU) 2024/232 of 25 October 2023 added entry 46, cadmium and lead in plastic profiles made from recovered rigid PVC for electrical and electronic windows and doors, at no more than 0,1 % cadmium and 1,5 % lead by weight: category 11, expiring on 28 May 2028.

The review: no ESPR merger, but a transfer to ECHA

The idea that RoHS is being folded into the ecodesign regulation has no basis in the texts. Report COM(2023) 760 final of 7 December 2023 concludes that the general review required by Article 24(2) will not be accompanied by a revision of the Directive, but by a targeted amendment re-attributing scientific and technical tasks to ECHA, and proposes no merger at all.

That amendment is now law. Directive (EU) 2025/2456 of 26 November 2025, in force on 1 January 2026, applies from 13 August 2027: applications to grant, renew or revoke an exemption go to ECHA rather than the Commission. The agency opens a three-month window for information, then asks the Committee for Socioeconomic Analysis for an opinion, and the Committee for Risk Assessment where a new exemption is at stake. Final opinions reach the Commission within twelve months of the completeness date. A draft delegated directive covering further lead and cadmium exemptions went out for feedback from 8 July to 5 August 2026 and drew 17 submissions: it is not adopted, and none of its expiry dates is settled.

How expiry actually works

An expiring exemption does not simply vanish. Article 5(5) requires a renewal application no later than eighteen months before expiry and keeps the existing exemption valid until the Commission decides. Article 5(6) adds that where a renewal is refused or an exemption revoked, it expires at the earliest twelve months and at the latest eighteen months after the decision. Recital 8 of Delegated Directive (EU) 2025/2364 shows this in practice: exemptions 6(a), 6(b) and 6(c) were to expire on 21 July 2023 for category 8 and on 21 July 2024 for categories 9 and 11, yet 6(a) and 6(b) stayed valid because renewal applications for those three categories had been filed on 20 January 2023.

Article 5(2) sets the initial validity: up to five years for categories 1 to 7, 10 and 11, and up to seven years for categories 8 and 9. Seven years is the exception, not the general rule. A decision currently takes eighteen to twenty-four months from the application date, according to the Commission.

What to do

Identify the exact sub-entry claimed for each leaded material and date it in the technical file: 11 December 2026 and 11 June 2027 land well before the 30 June and 31 December 2027 dates most of the block runs to.
Check general-public exposure for products relying on 6(a)-I, 6(a)-II, 6(b)-I, 6(b)-II, 6(b)-III or 6(c), which that footnote can exclude.
Revisit supplier declarations issued before 2026, and treat 39(a) as closed.