Lead exemptions
On January 13, 2025, the EU Commission published 3 draft delegated acts. Delegated acts can add amendments to existing legislation to reflect scientific progress. The draft delegated acts now published are intended to amend the validity dates and areas of application of some widely used exemptions from RoHS Directive 2011/65/EU Annex III as follows
- Hazardous substances - exemption for lead as an alloying element in steel, aluminum and copper
- 6(a): Expiry date (all categories): 12 months after entry into force of this delegated act
- 6(a)-I: Expiry date (all categories): December 31, 2026
- 6(a)-II: Expiry date (all categories): December 31, 2026
- 6(b): Expiration date (all categories): 12 months after the entry into force of this delegated act
- 6(b)-I: Expiry date (categories 1-7, 10): 12 months after entry into force of this delegated act; expiration date (categories 9 industrial, 11): December 31, 2026
- 6(b)-II: Expiry date (categories 1-7, 10): 12 months after the entry into force of this delegated act; expiration date (categories 9 industrial, 11): December 31, 2026
- 6(b)-III: Expiry date (categories 1-8, 9 non-industrial, 10): December 31, 2026
- 6(c): Expiration date (all categories): December 31, 2026
- Dangerous substances - exemption for lead in refractory solders
- 7(a): Expiry date (all categories except Annex III No. 24): December 31, 2026
- 7(a)-I: NEW; Expiry date (all categories except Annex III No. 24): December 31, 2027
- 7(a)-II: NEW; Expiry date (all categories except Annex III No. 24): December 31, 2027
- 7(a)-III: NEW; Expiry date (all categories except Annex III No. 24): December 31, 2027
- 7(a)-IV: NEW; Expiry date (all categories except Annex III No. 24): December 31, 2027
- 7(a)-V: NEW; Expiry date (all categories except Annex III No. 24): December 31, 2027
- 7(a)-VI: NEW; Expiry date (all categories except Annex III No. 24): December 31, 2027
- 7(a)-VII: NEW; Expiry datee (all categories except Annex III No. 24): December 31, 2027
- Dangerous substances - exemption for lead contained in electrical or electronic components made of glass or ceramics
- 7(c)-I: Expiry date (all categories): December 31, 2026
- 7(c)-II: Expiry date (all categories): December 31, 2027
- 7(c)-V: NEW; Lead in glass matrix for certain applications; Expiry date (all categories): December 31, 2027
- 7(c)-VI: NEW; Lead in ceramics for certain applications; expiration date: December 31, 2027
These draft acts are open for public comment from Januarry 13, 2025 to February 10, 2025. The feedback will be taken into account when finalizing these initiatives. The feedback received will be published on the EU Commission's website. These are frequently used lead exemptions, so it is advisable to submit feedback if you are affected (!). If these drafts are adopted unchanged, manufacturers, for example, must have replaced lead in connectors or PCB components within one year of their entry into force.
Exemptions list - validity and rolling plan December 2024
The EU Commission has updated its "RoHS 2 exemptions - Validity and rolling plan" (as of December 2024). The current status of the RoHS exemptions is documented here. The current version is dated December 02, 2024.
The following differences to the last version (August 2024) are recognizable
- Valid - requested for renewal
- Annex III - Exemption 45 for category 11
- Annex IV - Exemption 42 for categories 8 and 9
There is still no update regarding the validity of 117 exemptions for which an extension was requested in good time ("Valid - requested for renewal" status). These exemptions remain valid until the EU Commission publishes a corresponding delegated act.
For further support and questions, please do not hesitate to contact us.
Author
Linda Kritzler (B. A.)
Material & Environmental Compliance Consultant
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 how they may be placed on the market.
