EU RoHS — Lead Exemptions
RoHS Annex III exemption 6(b) (lead in aluminium) was not renewed in its general form. For product categories 1–7 and 10, sub-exemption 6(b)-I (recycled scrap aluminium) ceases to apply on 11 December 2026 and 6(b)-II (machining aluminium) on 11 June 2027 — fixed dates. Exemptions 6(c) (up to 4% lead by weight in copper alloys) and 7(c)-I (lead in glass or ceramic, other than capacitor dielectric ceramic) were set to expire on 30 June 2027, with narrower new entries 7(c)-V and 7(c)-VI listed to 31 December 2027 — but renewal requests filed in December 2025 have suspended those dates. Under Article 5(5) of the RoHS Directive, an exemption with a timely renewal request stays valid until the European Commission decides on it. Manufacturers relying on 6(b)-I or 6(b)-II in categories 1–7 and 10 need the lead use substituted before the fixed dates; those relying on 6(c) or 7(c)-I need to track a decision that, if negative, starts a 12- to 18-month phase-out.
Last updated 11 September 2026
Exemption 6(b) covered lead as an alloying element in aluminium containing up to 0.4% lead by weight, and was not renewed in its general form. Commission Delegated Directive (EU) 2025/2364, published on 21 November 2025 and in force since 11 December 2025, sets the end dates for its sub-exemptions. For product categories 1–7 and 10, 6(b)-I (lead that stems from recycling lead-bearing aluminium scrap) ceases to apply on 11 December 2026, and 6(b)-II (aluminium for machining purposes) on 11 June 2027. For category 9 industrial monitoring and control instruments and category 11, both are listed to 30 June 2027. A new, narrower 6(b)-III covers aluminium casting alloys containing up to 0.3% lead from recycled scrap, also listed to 30 June 2027, and renewal requests filed in December 2025 have suspended some of these 30 June 2027 aluminium dates, 6(b)-III included. A product in categories 1–7 or 10 placed on the EU market after 11 December 2026 or 11 June 2027 that still relies on 6(b)-I or 6(b)-II respectively is non-compliant.
Source: TÜV Rheinland; TecEx Global Compliance; Greensoft Technology.
Exemption 6(c) covers copper alloy containing up to 4% lead by weight — a routine allowance across connectors, contacts and mechanical hardware. Exemption 7(c)-I covers electrical and electronic components containing lead in a glass or ceramic other than dielectric ceramic in capacitors, such as piezoelectronic devices, or in a glass or ceramic matrix compound. Delegated Directives (EU) 2025/2364 and 2025/2363 set both to expire on 30 June 2027 for all categories, and added two narrower entries covering uses of 7(c)-I — 7(c)-V (lead in glass for specific functions such as sealing, bonding, resistive materials and microchannel plates) and 7(c)-VI (lead in PZT piezoelectric and PTC ceramics) — listed to 31 December 2027. The renewal-application deadline for the 30 June 2027 dates was 31 December 2025, and renewal requests for both 6(c) and 7(c)-I were filed in December 2025, the 7(c)-I request also covering 7(c)-V and 7(c)-VI. Under Article 5(5) of the RoHS Directive, an exemption with a timely renewal request stays valid until the Commission decides on it; if renewal is refused, the exemption ends 12 to 18 months after that decision. So 30 June 2027 is no longer the operative date for either exemption, but nor is it an extension: the outcome is still open.
Source: TÜV Rheinland; LEMO; Source Intelligence; Greensoft Technology.
A manufacturer whose product depends on one of these exemptions has two routes: substitute the restricted lead use with a compliant alternative before the exemption ceases to apply, or rely on a renewal. Renewal applications are made to the European Commission under Article 5 of the RoHS Directive no later than 18 months before the expiry date, with evidence that substituting or eliminating the lead is not yet scientifically or technically practicable; for the 30 June 2027 and 31 December 2027 entries those windows closed on 31 December 2025 and 30 June 2026. Whichever route applies, the product's own RoHS technical documentation, typically prepared to the harmonised standard EN IEC 63000, should hold the evidence supporting any exemption it relies on, and be kept current as those entries change. A product placed on the EU market after its exemption has ceased to apply, without a substitution in place, can no longer legally be sold on the strength of that exemption.
Source: Assent; Source Intelligence.
This runs on the same clock as CE/UKCA marking and CRA reporting but is a separate technical file — RoHS compliance is proven through material declarations, supplier documentation and technical documentation recording which exemptions a product relies on. We scope which RoHS exemptions a product's bill of materials actually depends on, check them against the fixed 11 December 2026 and 11 June 2027 dates and the pending 6(c) and 7(c)-I renewal decisions, and manage the substitution decision and paperwork against the real deadline.
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