On November 21, 2025, the 3 Delegated Directives on RoHS on the expiry or splitting of the lead exemptions of the 6, 7a and 7c series were published in the Official Journal. These will enter into force 20 days after publication on December 11, 2025.
This also results in the expiration dates of the exemptions, which expire 12 and 18 months after entry into force and cannot be extended. The now completed expiration dates are as follows:
| Delegated acts | Exemption | Expiration date | Extension period |
| 6(a)- 6(c) Hazardous substances - exemption for lead as an alloying element in steel, aluminum and copper | 6a | December 11, 2026 (will be split) | Not renewable |
| 6a-I and 6a-II (NEW) | June 30, 2027 | December 31, 2025 | |
| 6b | June 11, 2027 (will be split) | Not renewable | |
| 6b-I | December 11, 2026 (GK) 1-7, 10 June 11, 2027 GK 9 ind, 11 | Not renewable Not renewable | |
| 6b-II | June 11, 2027 for GK 1-7, 10 June 30, 2027 GK 9 ind, 11 | Not renewable December 31, 2025 | |
| 6b-III (NEW) | June 30, 2027 GK 1-10 (excl. 9ind) | December 31, 2025 | |
| 6c | June 30, 2027 | December 31, 2025 | |
| 7(a) Hazardous substances - exemption for lead in high melting temperature type solders | 7a | June 30, 2027 (will be split) | December 31, 2025 |
| 7a-I to 7a-VII (all NEW) | December 31, 2027 | June 30, 2026 | |
| 7(c)-I - 7(c)-VI Hazardous substances - exemption for lead in glass or in ceramic of electrical and electronic components | 7c-I | June 30, 2027 | December 31, 2025 |
| 7c-II | December 31, 2027 | June 30, 2026 | |
| 7c-V (NEW) | December 31, 2027 | June 30, 2026 | |
| 7c-VI (NEW) | December 31, 2027 | June 30, 2026 |
What does this mean for companies?
- Check whether the non-renewable exemptions are affected to ensure your security of supply - the affected applications must be substituted by the expiration dates
- The expiry dates of the renewal applications for the remaining RoHS exemptions are remarkably short (until December 31, 2025/ June 30, 2026) - here, too, it is essential to carry out an impact analysis in order to be able to contribute to the renewal applications if necessary.
As a reminder: a finished end device is not RoHS-compliant if an installed component contains lead in an increased concentration without being able to use a valid exemption. The declaration level is the homogeneous material, not the entire finished device.
Do you have any questions on the article "Official Journal listing RoHS exemptions"? We will be happy to provide you with further assistance. Simply send us an email with your question or use our contact form.
For more basic knowledge on RoHS and other material compliance topics, we recommend:
→ Material Compliance in the EU (REACH, RoHS, SCIP and more) or read
→ Official Journal listing of delegated acts
Author's note
This article has been machine translated into English.
DEFINITIONS AND ABBREVIATIONS
RoHS: Restriction of Hazardous Substances. The RoHS Directive 2011/65/EU aims to limit the use of certain hazardous substances in electrical and electronic products. It specifies how hazardous substances may be used in electrical appliances and electronic components and placed on the Chinese market.
