EU RoHS Exemptions: Mapping the 2026–2027 Expiry Dates

  News     |      2026-09-08 15:07

Three EU delegated directives have reshaped several widely used RoHS exemptions for lead. Commission Delegated Directives (EU) 2025/1802, 2025/2363 and 2025/2364 were adopted on 8 September 2025, published in the Official Journal on 21 November 2025 and required Member States to apply their provisions from 1 July 2026. EUR-Lex now provides a consolidated version of Directive 2011/65/EU dated 1 July 2026.

This is not a single blanket extension. Lead in high-melting-temperature solders, glass and ceramic components, and steel, aluminium or copper alloys now follows a mixture of phase-out entries, narrower sub-entries, category-specific dates and additional conditions. A supplier declaration that cites only a legacy reference such as 6(a), 6(b), 6(c), 7(a) or 7(c) may no longer provide enough information for a current technical file.

Expiry, pending renewal and a granted extension are different states

Article 5 of Directive 2011/65/EU allows specific material-and-component applications to be listed in Annex III or Annex IV when the legal criteria are met. Each exemption is time-limited and periodically reassessed against the availability and reliability of substitutes and the wider environmental, health, safety and socioeconomic effects of substitution.

The Commission’s implementation guidance draws an important distinction:

  • Timely renewal request: an existing exemption remains valid until the Commission decides on the request. A positive decision sets a new expiry date; a rejection normally provides a 12-to-18-month transition period.
  • No timely renewal request: the exemption expires on the date set by Article 5 or the applicable Annex entry.
  • Request for a new exemption: filing the request does not create interim coverage. Equipment must meet the current substance restrictions until a granting decision is adopted.

A renewal application is generally due at least 18 months before expiry. As of 8 September 2026, the Commission says that an exemption decision typically takes 18 to 24 months. Compliance records should therefore capture not only a date, but also whether a request was timely, whether a decision has been adopted and whether the resulting text is already applicable.

7(a): one broad solder reference is being replaced by seven use cases

Directive 2025/1802 reorganised Annex III point 7(a). The phase-out 7(a) entry still covers high-melting-temperature solders containing at least 85% lead by weight, applies to all EEE categories except applications covered by point 24, and expires on 30 June 2027.

New points 7(a)-I to 7(a)-VII separate semiconductor internal interconnections, die attach subject to defined thermal and electrical properties, first-level solder joints, specified BGA or high-temperature-overmoulding second-level joints, defined hermetic seals, connections in particular lamp types and audio transducers operating above 200°C. These sub-entries expire on 31 December 2027.

Lead content and melting point alone are no longer a complete basis for a claim. The evidence may need to identify the interconnection level, component architecture, current or voltage, die dimensions, thermal and electrical conductivity, overmoulding temperature or end application.

7(c): glass and ceramic claims now turn on function and electrical conditions

Directive 2025/2363 refines the glass and ceramic entries:

  • 7(c)-I covers defined lead-containing glass, ceramic or matrix-compound applications across all categories and expires on 30 June 2027.
  • 7(c)-II covers lead in dielectric ceramic in capacitors rated at 125 V AC or 250 V DC or higher, subject to its exclusions, and expires on 31 December 2027.
  • 7(c)-V specifies functions including protection or insulation in certain glass structures, hermetic sealing, bonding within a defined process window, resistive materials and particular modified glass surfaces. It expires on 31 December 2027.
  • 7(c)-VI covers defined PZT piezoelectric and PTC ceramic functions, excluding applications already covered elsewhere, and expires on 31 December 2027.

Descriptions such as “ceramic capacitor” or “glass package” are not enough on their own. Rated voltage, material function and overlap with another exemption can change the applicable route.

The 6-series alloy entries have several near-term dates

Directive 2025/2364 addresses lead in steel, aluminium and copper alloys. The schedule is not uniform:

  • The legacy 6(a) entry expires on 11 December 2026. New 6(a)-I for machining steel and 6(a)-II for batch hot-dip-galvanised steel components expire on 30 June 2027.
  • 6(b) expires on 11 June 2027. Dates for 6(b)-I and 6(b)-II vary by aluminium source, machining use and EEE category, falling on 11 December 2026, 11 June 2027 or 30 June 2027.
  • New 6(b)-III covers specified recycled-source aluminium casting alloys containing up to 0.3% lead for the listed categories until 30 June 2027.
  • 6(c), for copper alloys containing up to 4% lead, expires on 30 June 2027.

A new footnote also aligns the affected alloy entries with the REACH restriction on lead exposure from articles that children may place in their mouths. Relevant EEE or accessible parts supplied to the general public are generally outside the exemption unless both the lead-release and, where applicable, coating-durability conditions can be demonstrated. A dimension below 5 cm, or a detachable or protruding part of that size, is one of the criteria used in the text.

Build an exemption matrix that can survive a design review

  1. Fix the product and category. Record the model, variant, destination Member State, planned placing-on-the-market date and Annex I EEE category.
  2. Locate the homogeneous material and function. Map solder joints, steel parts, aluminium parts, copper-alloy fittings, glass packages and ceramic components to exact part numbers and locations.
  3. Migrate legacy references. Review every declaration, report and conformity record that cites a broad 6-series or 7-series entry. Add the current sub-entry, technical condition, category and expiry date.
  4. Separate evidence types. Chemical reports support concentration data, while drawings, specifications, design records and technical supplier declarations may be needed to prove component function and operating conditions.
  5. Create timed gates. Track at least 11 December 2026, 11 June 2027, 30 June 2027 and 31 December 2027, while monitoring timely renewal requests and final Commission decisions.
  6. Reassess changes. A new supplier, alloy grade, solder process, component rating, part geometry or EEE category can invalidate the original mapping.

What testing can and cannot establish

RoHS chemical testing can verify concentrations of lead and other restricted substances in homogeneous materials. It can provide useful evidence for material substitution, supplier changes and an exemption review. A laboratory result alone, however, usually cannot determine an interconnection level, the functional role of a glass or ceramic material, the EEE category or the legal status of a renewal request.

A stronger file connects test results to the BOM, drawings, specifications, supplier declarations, exemption matrix and placing-on-the-market schedule. An exemption addresses one restricted substance in one defined application. It is not a finding that the finished product complies with all RoHS requirements or any other CE legislation.

How Qianxin can support readiness

For a defined product, material set, destination market and written scope, Qianxin can support component and homogeneous-material grouping, identification of RoHS substance-testing needs, sample-to-BOM and part-number checks, and a preliminary completeness review of supplier declarations, reports and technical records. Final legal applicability, renewal status, national transposition and the responsibilities of EU economic operators remain product- and fact-specific decisions for the responsible parties.

This article is based on European Commission and EUR-Lex material publicly available on 8 September 2026. It summarises three recent Annex III amendment packages rather than the complete RoHS exemption list and is not a substitute for product-specific legal advice or a final conformity assessment.

Official Sources