On November 21, in their Official Journal, the EU published an amendment to Annex III of the RoHS Directive (2011/65/EU) concerning modification, renewal, and expiration of several widely-used RoHS exemptions.
On December 11, 2025, the changes to the RoHS Directive will enter into force, beginning a 12- to 18-month transition period for expiring exemptions.
Specifically, manufacturers may anticipate upcoming changes to the following exemptions.
| Exemption | Substance Exempted and Application(s) |
| 6(a) | Lead as an alloying element in steel |
| 6(b) | Lead as an alloying element in aluminum |
| 6(c) | Lead in copper alloy |
| 7(a) | Lead in High-Temperature Solders |
| 7(c)-I/7(c)-II | Lead in Glass/Ceramic components; Lead in dielectric ceramic capacitors |
Exemption 6(a) changes
Exemption 6(a) is not renewed. It expires December 11, 2026.
Exemption 6(a)-I is split into two exemptions that will expire June 30, 2027 for all article categories.
| 6(a)-I | Renewed for machining purposes, containing up to 0.35% lead by weight |
| 6(a)-II | New exemption for batch hot-dip galvanized steel, decreasing from 0.35% to 0.2% lead by weight |
Exemption 6(b) changes
Exemption 6(b) is not renewed. It expires June 11, 2027.
Exemption 6(b)-I (scrap) is not renewed for categories 1-7 & 10. It expires December 11, 2026. It is retained for categories 9 and 11 until June 30, 2027.
Exemption 6(b)-II (for machining purposes) is not renewed for categories 1-7 & 10. It expires June 11, 2026. It is retained for categories 9 and 11 until June 30, 2027.
Exemption 6(b)-III (for casting alloys) continues the exemption, but is limited to 0.3% lead by weight from recycled aluminum scrap. The exemption expires June 30, 2027 for categories 1-8, 9 (other than industrial), and 10.
Exemption 6(c) changes
Exemption 6(c) is renewed for all categories and expires June 30, 2027. Lead content remains at 4% by weight.
Exemption 7(a) changes
Exemption 7(a) is renewed for all categories. It is set to expire June 30, 2027 for all categories.
New 7(a) sub-exemptions are created for specific applications. These new sub-exemptions expire December 31, 2027.
| 7(a)-I | Semiconductor die attachments for internal chip interconnections with specific electrical or physical characteristics. |
| 7(a)-II | Die attach materials requiring high thermal and electrical conductivity meeting specific thresholds and solidus melting temperatures. |
| 7(a)-III | First-level solder joints in component manufacturing designed to prevent reflow during subsequent mounting. This excludes die attach and hermetic sealing. |
| 7(a)-IV | Secondary solder joints used in specific conditions, such as solder balls for ceramic BGA attachment or high-temperature plastic overmouldings. |
| 7(a)-V | Hermetic sealing material between ceramic packages/plugs and metal cases. |
| 7(a)-VI | Internal electrical connections in certain lamps, such as incandescent, infrared heating, and oven lamps. |
| 7(a)-VII | Audio transducers operating at peak temperatures above 200°C. |
Exemption 7(c)-I changes
Exemption 7(c)-I is renewed and expires June 30, 2027 for all categories.
New sub-exemptions are created for specialized glass and ceramic applications. These new sub-exemptions expire December 31, 2027.
| 7(c)-V | Lead in glass or glass-matrix compounds. |
| 7(c)-VI | Lead in functional ceramics. |
Exemption 7(c)-II changes
Exemption 7(c)-II is renewed and expires December 31, 2027 for all categories.
As continued updates from the European Commission are released and published, QPoint Technology remains ready to provide you solutions to the challenges presented by regulations like the EU RoHS Directive. If you are looking to improve your data, reporting capabilities, and develop operational efficiency around managing compliance, consider looking at Green Data Exchange (GDX) today!
