Published 10/08/26
Between September and November 2025, the European Commission adopted three Delegated Directives amending Annex III of the RoHS Directive (2011/65/EU): 2025/1802, 2025/2363 and 2025/2364. Together they rewrite the lead exemptions in the 6, 7(a) and 7(c) series, covering lead in metal alloys, high melting temperature solders, and glass or ceramic components.
Member States had until 30 June 2026 to transpose the changes. The new provisions have applied since 1 July 2026.
If your products cite any exemption in these three series, this is worth going through properly now rather than finding out at an audit that the wording you're relying on has already changed.
Series 6: lead in steel, aluminium and copper
Covered by Delegated Directive 2025/2364. 6(a), 6(b) and 6(c) are retained but redefined, with new sub points added for specific applications:
- 6(a) (lead in steel for machining and galvanised steel, up to 0.35% by weight): retained, expires 11 December 2026 but now has two new sub points, 6(a)-I and 6(a)-II, covering machining and hot dip galvanising separately, both expiring 30 June 2027.
- 6(b) (lead in aluminium, up to 0.4% by weight): retained, expires 11 June 2027, alongside three new sub points covering recycled content, machining, and casting alloys, with expiry dates that vary by product category.
- 6(c) (copper alloy containing up to 4% lead by weight): retained, expires 30 June 2027.
Series 7(a): lead in high melting temperature solders
Covered by Delegated Directive 2025/1802. The old single point 7(a) covered a broad range of solder applications under one entry. It's now split into seven sub points, 7(a)-I through 7(a)-VII, each tied to a specific application: internal interconnections, die attach, first and second level solder joints, hermetic sealing materials, high melting temperature solder in certain lamps, and audio transducers. All seven expire 31 December 2027.
The effect of this change is that a general citation of "7(a)" no longer describes your product precisely enough. You need to identify which of the seven sub points actually matches your application and cite that one instead.
The 7(c) series: lead in glass and ceramic components
Covered by Delegated Directive 2025/2363. 7(c)-I and 7(c)-II are redefined, and two new points are added:
- 7(c)-I: components containing lead in a glass or ceramic other than dielectric ceramic in capacitors, for example piezoelectric devices or a glass or ceramic matrix compound. Applies to all categories, expires 30 June 2027.
- 7(c)-II: lead in dielectric ceramic in capacitors rated at 125V AC or 250V DC or higher. Applies to all categories except where 7(c)-I or the new 7(c)-IV applies, expires 31 December 2027.
- 7(c)-V (new): lead in glass or glass matrix compounds for specific functions such as high voltage insulation, sealing, and resistive materials. Expires 31 December 2027.
- 7(c)-VI (new): lead in functional ceramics such as piezoelectric (PZT) and PTC thermistor materials. Expires 31 December 2027.
As with 7(a), the split means a product that was covered by the old, broader 7(c)-I wording needs to be checked against the new, narrower version and against 7(c)-V or 7(c)-VI to see which one actually applies now.
What this means for you.
To check whether these changes affect your product, revisit your technical file and check whether any RoHS exemptions sit in the 6, 7(a) or 7(c) series. If they do, match each one to its new sub point rather than the previous generic number, and confirm the expiry date for your specific product category, since several now vary by category rather than being uniform. Any exemptions currently used in the product which are set to expire must become a priority to address. If a material used in the product RoHS exemption is set to expire, start supplier conversations now to ensure a smooth transition to lead-free alternative and update your technical file and Declaration of Conformity to the correct current exemption once confirmed. None of these changes make a product non-compliant as of July 2026. However it means the exemption basis for products across these three series is shifting on a fixed timeline towards new requirements, and it is the responsibility of the manufacturer to keep products in line with the directive.
If you require assistance with compliance with the RoHS Directive 2011/65/EU get in touch at
Sources
- European Commission, Delegated Directive (EU) 2025/2364 (6 series), EUR-Lex: https://eur-lex.europa.eu/legal-content/EN/PIN/?uri=oj%3AL_202502364
- European Commission, Delegated Directive (EU) 2025/1802 (7(a) series), EUR-Lex: https://eur-lex.europa.eu/eli/dir_del/2025/1802/oj
- European Commission, Delegated Directive (EU) 2025/2363 (7(c) series), EUR-Lex: https://eur-lex.europa.eu/eli/dir_del/2025/2363/oj/eng