In January 2025, the EU Commission presented three drafts of delegated acts. They relate to exemptions 6a-c, 7a and 7c on lead in the RoHS Directive 2011/65/EU. The fact that December 31, 2026 is the deadline for some exemptions is understandably causing concern. The finalizations of the delegated acts were published on September 08, 2025 and will enter into force 20 days after publication in the Official Journal.
- The good news is that this date has been pushed back.
- The bad news: only by six months.
In order to submit renewal applications for these new expiry dates in good time (18 months before expiry), applications for exemptions with an expiration date of June 30, 2027 must be received by December 31, 2025. The exemptions with an earlier expiration date (less than 18 months) will expire without the possibility of applying for an extension. Split exemptions have been created for specific applications of 6a and 6b, for which corresponding extensions must be applied for.
Key points of the delegated acts
6a-c: Lead as an alloy component (steel, aluminum, copper)
- 6a: 12 months after entry into force; splinter exemptions apply in parallel
- 6b: 18 months after entry into force; splitter exemptions apply in parallel
- 6a-I and 6a-II (NEW): June 30, 2027
- 6b-I: 12 months after entry into force for device categories (GK) 1-7, 10
- 6b-I: 18 months after entry into force for GK 9 ind, 11
- 6b-II: March 28, 2027 for GK 1-7, 10;
- 6b-II: June 30, 2027 for GK 9 ind, 11
- 6b-III (NEW): GK 1-10 (excl. 9ind): June 30, 2027
- 6c: june 30, 2027
7a: Lead in high temperature solders
- 7a: June 30, 2027; splinter exceptions become valid in parallel
- 7a-I to 7a-VII (all NEW): December 31, 2027
7c: Lead in glass/ceramics
- 7c-I: June, 30 2027
- 7c-II: December 31, 2027
- 7c-V (NEW) and 7c-VI (NEW): December 31, 2027
What does this mean for companies
- Prioritize portfolio: Which devices and components use the relevant exemptions? Evaluate high-risk applications first (alloys, critical solders, glass/ceramics), pay attention to the splitting of exemptions
- Sensitize supply chain: Explicitly inquire about specific sub-entries
- Promote substitution: Where technically feasible, test lead-free alternatives and processes; document test results
- Observe expiration dates of non-renewable exemptions! (12 months after entry into force)
- Submit extension applications if necessary, or support trade associations in obtaining information
- Keep technical documentation up to date, extract information from supply chain communication
- Plan roadmap & transition periods: The direction is clear: precise use cases, shorter terms. Prepare changeovers now to avoid later recalls and other corrective measures or sanctions
- Establish legal monitoring: Keep an eye on drafts, finalizations, consolidations and deadlines
Conclusion: Sooner or later, the EU will tighten the lead exemptions. Those who create transparency and check substitutions today will be compliant and future-proof tomorrow.
Read also → EU: RoHS exemptions update January 2025
Exemptions list - validity and rolling plan July 2025
The EU Commission has updated its "RoHS 2 exemptions - Validity and rolling plan" (as of July 2025). The current status of the RoHS exemptions is documented here.
The following differences to the last version (December 2024) are recognizable
Annex III
- 1(f)-Il: "Mercury in single-ended (compact) fluorescent lamps that do not exceed the following values (per lamp): For specific uses: 5 mg"
- Expired: February 24, 2025 (No longer valid)
- 2(b)(III): "Non-linear tri-phosphor lamps with a tube diameter of > 17 mm (e.g. T9): 15 mg"
- Expired: February 24, 2025 (No longer valid)
- 3(a-c): "Mercury in CCFL (cold cathode fluorescent lamps) and EEFL (external electrode fluorescent lamps) lamps for specific uses in electrical and electronic equipment placed on the market before February 24, 2022, not exceeding the following values (per lamp):
- a. Short lamps (≤ 500 mm): 3.5 mg
- b. Medium length lamps (> 500 mm and ≤ 1 500 mm): 5 mg
- c. Long lamps (> 1 500 mm): 13 mg"
- Expired: February 24, 2025 (No longer valid)
- 9(a)-IIl: "Hexavalent chromium as corrosion inhibitor up to a mass fraction of 0.7% in the closed loop carbon steel working fluid of gas absorption heat pumps for space and water heating"
- Expiration date: December 31, 2026 (Valid - no longer renewable)
Annex VI
- 42: "Mercury in rotary transducers in intravascular ultrasound imaging systems suitable for high operating frequency modes (> 50 MHz)."
- Expiration date: June 30, 2026 (Valid - requested for renewal)
Do you have questions about other RoHS exemptions? We are at your disposal for further support. Simply send us an e-mail with your question or use our contact form.
Author's note
This article has been machine translated into English.
DEFINITIONS AND ABBREVIATIONS
RoHS, EU Directive 2011/65/EU aims to limit the use of certain hazardous substances in electrical and electronic equipment. It specifies how hazardous substances may be used in electrical appliances and electronic components and placed on the market.
