EU RoHS Compliance in 2026: What to Expect

EU RoHS compliance in 2026 will be shaped less by new substance restrictions and more by tightening EU RoHS lead exemptions, revised lead thresholds, and approaching renewal and expiration deadlines. While the restricted substances list remains unchanged, manufacturers must prepare for delegated directive updates taking effect in 2026 that will significantly impact how exemptions are managed across products and materials. 

Businesses subject to the EU Restriction of Hazardous Substances Directive (EU RoHS) must stay focused on exemption tracking, supplier data accuracy, and defensible documentation to maintain compliance as new requirements are transposed and implemented across Member States. 

What are the latest revisions to the EU RoHS Directive?

Regulatory attention has shifted toward narrowing existing EU RoHS exemptions in 2026. This is particularly true for those related to lead use in electrical and electronic equipment. In November 2025, the European Commission adopted new delegated directives revising multiple RoHS exemptions, with implementation milestones set for 2026. 

EU RoHS exemption expirations to monitor in 2026

EU RoHS compliance risk in 2026 is tied to the revision of some existing exemptions, the addition of some new exemptions, as well as changes to their scope and expiry dates.  

Recent delegated directives have aligned, refined, or narrowed several lead-related exemptions. While many of these exemptions extend into 2027, 2026 is a critical preparation year, since it is when the delegated directives enter into force. This means companies must determine whether substitution is feasible or whether renewal justification is required. 

After exemptions expire, manufacturers must either: 

• Substitute restricted substances with compliant alternatives, or 
• Justify why substitution is not yet technically feasible. 

Both paths require accurate material data and strong supplier documentation well in advance of enforcement. 

EU RoHS exemption renewals and revised scope 

Many of these updates affect EU RoHS Annex III exemptions, which apply broadly across electrical and electronic equipment categories. Certain revisions also impact EU RoHS Annex IV exemptions, which apply specifically to medical devices and monitoring and control instruments. Several commonly used exemptions under EU RoHS have been revised rather than eliminated, sometimes splitting exemptions into multiple new ones. These changes increase specificity and reduce flexibility, placing greater emphasis on use-case accuracy and renewal readiness. 

Directive (EU) 2024/232: recovered PVC exemptions

Directive (EU) 2024/232, published in January 2024, amended Directive 2011/65/EU to introduce a specific exemption for cadmium and lead in recovered rigid polyvinyl chloride used in electrical and electronic windows and doors. 

Key provisions include: 

• Cadmium concentration must not exceed 0.1% by weight 
• Lead concentration must not exceed 1.5% by weight 
• Articles containing recovered PVC with lead concentrations at or above 0.1% must be clearly marked 
• From May 28, 2026, recovered PVC from electrical and electronic windows and doors may only be used for specified applications 

This exemption, entry 46 in Annex III, expires on May 28, 2028, and reflects the EU’s broader effort to balance circularity goals with tightened substance controls. 

Directive (EU) 2024/1416: quantum dot exemptions

Directive (EU) 2024/1416 further amended EU RoHS by updating exemptions related to cadmium-based semiconductor nanocrystal quantum dots used in display technologies. 

Updates include: 

• The expiry date for entry 39(a) is updated to November 21, 2025 

• Entry 39(b), a new exemption for cadmium quantum dots directly deposited on LED semiconductor chips, expires on December 31, 2027 

EU Member States should have adopted and published the necessary provisions by July 31st, 2024. The provisions applied on August 1st, 2024. 

Interested in the difference between EU REACH, RoHS, and CE?  

Read our blog, EU REACH vs. RoHS vs. CE to learn more about the key differences between them, important overlaps, and how they affect your compliance strategy.  

EU RoHS delegated directive updates taking effect in 2026

In November 2025, the European Commission released delegated directives revising several lead-related exemptions. The EU RoHS transposition deadline requires Member States to transpose these changes by June 30, 2026, with provisions taking effect July 1, 2026. 

Directive (EU) 2025/1802: high melting temperature solder exemptions

The previous single exemption for high melting temperature solders, entry 7(a), has been refined into seven clearly defined subcategories, reflecting different technical applications such as semiconductor interconnects, hermetic seals, and high-temperature lighting components. 

Key compliance dates: 

• All subcategories expire at the end of 2027. 
• Renewal applications are due by June 2026. 
• Important note: a renewal application has been submitted December 12, 2025, covering entry 7(a) and new entries 7(a)-I through 7(a)-VII. This means that the expiry date is currently suspended, pending the resolution of this request. 

Companies relying on these exemptions must confirm correct categorization and prepare renewal documentation early. 

Directive (EU) 2025/2364: metal alloy exemptions under EU RoHS

Metal alloy exemptions under EU RoHS are getting more specific, more time-bound, and harder to justify over time. The latest delegated directive keeps some pathways open, but it also lowers lead thresholds, narrows exemption scope, and sets clearer phase-out expectations. If your products rely on steel, aluminum, or copper alloys, now is the time to validate material choices and plan for redesigns before enforcement pressure ramps up. 

Steel exemptions are refined with the addition of a new item, and are aligned to new expiry dates. 

• Exemption 6(a)-I has been split in two, allowing more precise identification. 
• Expiry dates have been updated to June 2027. However, these have been the subject of a renewal request placed in December 2025, suspending their expiry dates. 
• Exemption 6(a) will expire in December 2026 with no further renewal possible. 
• A new substitution study is required by the end of 2026. 

Aluminum exemptions tighten significantly, especially for recycled aluminum applications. 

• The lead cap for recycled aluminum is reduced to 0.3%, with quantities up to 0.4% expiring in late 2026 for most categories. 
• The machined aluminum exemption is phased out by mid-2027. 
• A new, narrower exemption is introduced for recycled cast aluminum until 2027. 
• Requests for renewal placed in December 2025 have suspended the expiry dates for some of these exemptions. 

Copper alloys may continue to contain up to 4% lead through 2027, but product-specific limits still apply. 

• Products accessible to children must still meet strict lead release limits. 
• A renewal request has been submitted in December 2025 for this exemption, too, meaning the expiry date is suspended. 

Directive (EU) 2025/2363: glass and ceramics exemptions 

The former broad exemption for glass and ceramics (item 7(c)-I) has been split into targeted categories, including functional ceramics and high-voltage ceramic capacitors. These exemptions are extended until December 31, 2027. 

However, this expiry date for exemptions 7(c)-I, II, V and VI is suspended due to a renewal request submitted in December 2025. 

Preparing for EU RoHS compliance in 2026

Although many exemptions extend into 2027, 2026 is the year to prepare. Companies should use this window to: 

• Validate which exemptions apply at the product and material level 
• Confirm supplier declarations reflect revised thresholds and scope 
• Identify where substitution is feasible versus where justification will be required 
• Strengthen documentation ahead of renewal and enforcement deadlines 

Delayed preparation increases the risk of last-minute redesigns, supply chain disruption, or non-compliance findings during audits. 

For a more detailed look at 2026 compliance obligations across multiple industries, watch our webinar, Regulatory Changes to Expect in 2026.  

Stay ahead of EU RoHS compliance changes with Source Intelligence

Managing EU RoHS compliance is becoming more demanding as exemptions expire, substance thresholds evolve, and enforcement tightens across regions. For companies navigating both EU RoHS and global RoHS regulations, manual tracking and fragmented supplier data create unnecessary risk. 

Source Intelligence’s expert software helps compliance teams keep pace with EU RoHS updates while aligning requirements across global RoHS frameworks. By centralizing RoHS data and automating key workflows, teams gain the visibility and control needed to maintain market access worldwide.  

Our global RoHS solution helps organizations: 

• Integrate RoHS data across systems and suppliers 
• Collect and validate supplier disclosures at scale 
• Identify RoHS risks faster 
• Track compliance status in real time 
• Generate RoHS documentation on demand 

By reducing manual effort and strengthening data defensibility, Source Intelligence enables teams to respond confidently to evolving EU RoHS requirements while staying aligned with global regulations. Explore our solution to learn how Source Intelligence supports EU RoHS compliance in 2026 and beyond.