EU Commission Adopts Key RoHS Lead Exemption Changes: What You Need to Know

The European Commission has finalized delegated directives amending Annex III of the RoHS Directive, which are expected to enter into force in late 2025. This will create new compliance challenges for manufacturers and suppliers: the revisions extend some expiry dates, introduce new sub-exemptions, and confirm transition periods for revoked exemptions.  

For companies in the electrical and electronics industry, these changes significantly affect product compliance strategies and supply chain planning. 

Substances and categories affected

The Commission has finalized updates for the following exemptions: 

• Lead in steel, aluminum, and copper alloys
• Lead in high-melting-temperature solders
• Lead in glass and ceramic components

Key structural changes include: 

• Addition of new exemptions 
• Removal of some exemptions 
• New expiry dates 

These refinements provide more clarity for specific applications while maintaining strict timelines for industry adaptation. 

Updated expiry dates for RoHS directive exemptions

Lead in steel, aluminum and copper alloys: 

• 6(a): Revoked, expires 12 months after entry into force 
• 6(a)-I, 6(c): Renewed, expires June 30, 2027 
• New category 6(a)-II: expires June 30, 2027 
• 6(b): Revoked, expires 18 months after entry into force 
• 6(b)-I: 
  • Revoked for categories 1–7 and 10, expires 12 months after entry into force 
  • Renewed for categories 9 IMCI and 11, expire June 30, 2027 
• 6(b)-II: 
  • Revoked for categories 1–7 and 10, expire 18 months after entry into force 
  • Renewed for categories 9 IMCI and 11, expire June 30, 2027 
• New category 6(b)-III: expires 30 June 2027 for categories 1–10 (excluding categories 9 IMCI and 11) 

There is also a new specification regarding the oral exposure of lead to children: for EEE meeting specific conditions that would make exposure a concern, these exemptions will not apply. 

Lead in high-melting-temperature solders: 

• 7(a): Renewed, expires June 30, 2027 
• New categories 7(a)-I through 7(a)-VII: expire December 31, 2027 

Lead in glass and ceramic components:

• 7(c)-I: Renewed, expires June 30, 2027 
• 7(c)-II: Renewed, expires December 31, 2027 
• New categories 7(c)-V and 7(c)-VI: expire December 31, 2027 

The directives will be published in the Official Journal of the EU (OJEU) and will also start the 12- or 18-month transition periods for revoked exemptions. 

Renewal application deadlines

To remain compliant, renewal requests must be submitted well before expiry: 

• For exemptions expiring June 30, 2027, renewal applications due December 31, 2025 
• For exemptions expiring December 31, 2027, renewal applications due June 30, 2026 

Revoked exemptions with 12- or 18-month phase-outs are not eligible for renewal. 

What these EU RoHS exemptions mean for manufacturers

For manufacturers, the final adoption of these RoHS directive exemptions brings greater clarity but also new compliance considerations. The EU continues to push for the reduction of hazardous substances, while acknowledging that full substitution remains technically challenging in certain applications. By splitting exemptions into more specific categories, the Commission has increased transparency and shortened review cycles. This means that manufacturers will face more frequent updates and closer scrutiny of exemption use. 

Action steps for staying compliant with RoHS exemptions

Staying compliant under the revised RoHS exemptions requires a proactive approach. Manufacturers should work closely with their supply chain to understand where exemptions apply, assess upcoming risks, and plan for alternatives well before deadlines. The following steps can help ensure a smoother compliance process: 

• Engage with suppliers – confirm which exemptions apply to your parts and components. 

• Map your risks – prioritize products covered by exemptions that will be revoked in 12–18 months. 

• Plan alternatives – begin testing and qualifying lead-free substitutes for alloys, solders, glass, and ceramics. 

• Prepare renewals – ensure applications are filed by December 2025 and June 2026. 

• Track official updates – monitor OJEU publications, as entry into force dates determine your compliance timeline.

How Source Intelligence simplifies RoHS directive exemption management

Manually tracking RoHS exemptions, coordinating with suppliers, and preparing renewal applications can quickly overwhelm internal teams. The finalized timelines only add pressure, with stricter requirements, shorter review cycles, and closer regulatory scrutiny. Without the right system in place, companies risk costly delays, supply chain disruptions, and compliance gaps. 

That’s where Source Intelligence comes in. Our RoHS compliance solution automates exemption tracking, streamlines supplier engagement, and manages renewal applications so you don’t have to. We deliver real-time monitoring of EU updates, simplified reporting, and audit-ready documentation — reducing compliance risk while giving your team back valuable time to focus on innovation. 

Need help navigating RoHS directive exemptions? Explore our RoHS solution to see how we simplify compliance and keep you ahead of regulatory change.