For years, manufacturers have relied on EU RoHS exemptions to continue using lead in specific applications where the substance remains technically necessary.

That does not mean those exemptions are permanent.

In September 2025, the European Commission adopted several delegated directives revising lead exemptions in Annex III of the RoHS Directive (2011/65/EU). The changes affect lead used as an alloying element in steel, aluminium and copper, lead in high-melting-temperature solders, and lead in glass and ceramic components. (EUR-Lex)

The amendments were published in the Official Journal on 21 November 2025. The directives entered into force 20 days after publication, while Member States must transpose them by 30 June 2026 and apply the national measures from 1 July 2026. (EUR-Lex)

For manufacturers of electrical and electronic equipment, the practical issue is therefore not simply:

"Does this product contain lead?"

It is:

"Which RoHS exemption applies to this lead-containing application, which sub-entry applies, what product category does it cover, and when does that exemption expire?"

That distinction is becoming increasingly important as the revised Annex III entries become more specific.

What Changed in the EU RoHS Lead Exemptions?

Lead remains a restricted substance under Annex II of RoHS, with a maximum tolerated concentration of 0.1% by weight in homogeneous materials. The restriction does not apply where a specific application is covered by an applicable Annex III exemption. (EUR-Lex)

The 2025 amendments revised three important groups of lead exemptions:

• Series 6: Lead as an alloying element in steel, aluminium and copper
• 7(a): Lead in high-melting-temperature solders
• 7(c): Lead in glass and ceramic components

The changes include:

• replacement of existing exemption wording;
• creation of new sub-entries;
• more specific descriptions of applications;
• different expiry dates for different applications;
• and, in some cases, different expiry dates depending on the RoHS product category. (EUR-Lex)

This means manufacturers should avoid treating "Exemption 6" or "Exemption 7(a)" as sufficient compliance data on its own.

EU RoHS Series 6 Lead Exemptions: Steel, Aluminium and Copper

The Commission's Delegated Directive (EU) 2025/2364 revises Annex III entries covering lead as an alloying element in steel, aluminium and copper. (EUR-Lex)

Current Series 6 exemption structure

Source: Commission Delegated Directive (EU) 2025/2364. (EUR-Lex)

What manufacturers should notice

The important point is that the expiry date is not identical across all Series 6 applications.

For example:

• some steel applications have an expiry of 11 December 2026;
• some revised steel sub-entries run to 30 June 2027;
• aluminium applications have different dates depending on the specific sub-entry and product category;
• copper alloy exemption 6(c) expires on 30 June 2027.

That makes exemption classification a product-data issue, not simply a regulatory-document issue.

RoHS Exemption 6(a): Lead in Steel

The revised 6(a) family distinguishes between the broader existing entry and the new sub-entries.

The Commission now provides:

• 6(a)-I for steel used for machining purposes with up to 0.35% lead by weight; and
• 6(a)-II for batch hot-dip galvanised steel components with up to 0.2% lead by weight.

Both sub-entries expire on 30 June 2027 for all categories.

The original 6(a) entry has an expiry date of 11 December 2026.

For manufacturers, this means that a generic supplier statement such as:

"Component contains lead under RoHS 6(a)"

does not provide the same level of information as:

6(a)-I → steel for machining → ≤0.35% Pb → applicable product category → expiry date

The latter can actually be managed inside a product compliance system.

RoHS Exemption 6(b): Lead in Aluminium

The revised aluminium exemptions are particularly important because the Commission now distinguishes between different sources and uses of lead-containing aluminium.

The revised entries include:

• 6(b) — aluminium containing up to 0.4% lead;
• 6(b)-I — aluminium containing up to 0.4% lead where the lead comes from lead-bearing aluminium scrap recycling;
• 6(b)-II — aluminium for machining purposes with up to 0.4% lead;
• 6(b)-III — aluminium casting alloys containing up to 0.3% lead where the lead comes from lead-bearing aluminium scrap recycling.

The expiry dates vary according to the entry and, in some cases, the product category.

This is precisely why manufacturers should capture the specific exemption sub-entry, rather than storing only the parent exemption number.

RoHS Exemption 6(c): Lead in Copper Alloys

The revised 6(c) entry covers:

Copper alloy containing up to 4% lead by weight.

The exemption expires on 30 June 2027.

For electronics manufacturers, copper-alloy applications can be particularly difficult to manage because the material may be several levels removed from the finished product manufacturer.

Examples can include:

• terminals;
• connectors;
• machined parts;
• electrical contacts;
• other copper-alloy components.

The compliance challenge is therefore not just identifying lead.

A New Consideration for Some Series 6 Applications

The revised Series 6 entries also contain a specific footnote concerning EEE supplied to the general public where the EEE or an accessible part could be placed in a child's mouth during normal or reasonably foreseeable use.

In those circumstances, the exemption does not apply unless specified lead-release and coating conditions can be demonstrated.

This is a good example of why manufacturers should not treat an exemption number as an automatic "pass."

The actual applicability depends on the specific application and conditions attached to the exemption.

RoHS Exemption 7(a): High-Melting-Temperature Solders

The Commission also revised RoHS exemption 7(a) through Delegated Directive (EU) 2025/1802.

The revised structure is much more detailed.

The parent 7(a) entry covers:

Lead in high-melting-temperature type solders, meaning lead-based alloys containing 85% by weight or more lead.

It expires on 30 June 2027.

The revised Annex III also establishes specific sub-entries 7(a)-I through 7(a)-VII.

Current RoHS 7(a) Structure

All of these entries apply to all categories except applications covered by point 24 of Annex III, subject to the wording of the individual entry.

Why the Revised 7(a) Structure Matters

It would be inaccurate to reduce the revised exemption to:

"Lead solder above 85% = exempt."

The legal text does retain the ≥85% lead definition for high-melting-temperature solder, but the revised sub-entries establish specific application conditions for particular uses.

For example, 7(a)-II contains specific conditions concerning:

• thermal conductivity;
• electrical conductivity; and
• solidus melting temperature.

Therefore, manufacturers need to know why and where the solder is being used, not merely its lead concentration.

RoHS Exemption 7(c): Lead in Glass and Ceramic Components

The Commission revised exemption 7(c) through Delegated Directive (EU) 2025/2363.

The revised text:

• replaces 7(c)-I;
• replaces 7(c)-II;
• adds 7(c)-V;
• adds 7(c)-VI.

Current 7(c) entries affected by the 2025 amendment

The precise category exclusions and cross-references in the legal wording should be checked before applying a particular sub-entry to a product.

What Is Covered by 7(c)-V?

The new 7(c)-V entry is highly specific.

It covers lead in glass or glass matrix compounds performing functions including:

1. protection and electrical insulation in glass beads of high-voltage diodes and glass layers for wafers;
2. hermetic sealing between ceramic, metal and/or glass parts;
3. bonding within a specified process-parameter window;
4. use as resistive material such as ink within the specified resistivity range; and
5. use in chemically modified glass surfaces for MCPs, CEMs and RGPs.

The exemption expires on 31 December 2027.

What Is Covered by 7(c)-VI?

The new 7(c)-VI entry concerns lead in ceramic used:

• in piezoelectric lead zirconium titanate (PZT) ceramics; or
• to provide ceramics with a positive temperature coefficient (PTC).

It expires on 31 December 2027, subject to the exclusions stated in the legal text.

What These Changes Mean for Electronics Manufacturers

The practical change is straightforward:

A lead-containing component cannot be managed effectively by substance information alone.

Manufacturers need to understand the relationship between the substance, the application and the applicable exemption.

A useful internal data structure is:

The exact values will obviously depend on the actual product and supplier evidence.

1. Your Supplier Declarations Need More Granularity

A declaration that says:

"RoHS compliant"

may tell you the overall result, but it does not necessarily tell you which exemption supports a lead-containing application.

Likewise, a declaration that simply states:

"RoHS exemption 7(a)"

does not capture the more specific sub-entry structure introduced by the 2025 amendment.

For internal compliance management, manufacturers should aim to capture the applicable exemption at the level necessary to demonstrate why the exemption applies.

2. Your BOM Should Be Connected to Exemption Data

The BOM does not need to become a regulatory document.

But your compliance system should be able to answer:

Which products contain components relying on an exemption that expires in 2026 or 2027?

That requires a relationship between:

BOM

→ Component

→ Material

→ Substance

→ Exemption

→ Expiry date

Without that relationship, an exemption expiry can remain buried inside a supplier PDF.

3. Exemption Expiry Should Trigger Action

An expiry date should not simply sit in a spreadsheet.

For example:

6(a) expiry approaching

↓

Identify affected components

↓

Identify affected products

↓

Review supplier evidence

↓

Assess alternative materials/components

↓

Engineering review

↓

Qualification/testing where required

↓

Update BOM

↓

Update technical documentation

This turns regulatory monitoring into an operational process.

4. Supplier Data Needs Continuous Maintenance

A supplier declaration can become outdated when:

• the component changes;
• the material changes;
• the supplier changes;
• the manufacturing process changes;
• an exemption changes;
• an exemption expires.

The objective should therefore be to maintain current product-level compliance evidence, rather than relying indefinitely on historical declarations.

5. IEC 63000 Should Be Treated as the Evidence Framework

IEC 63000 is relevant to the technical documentation used to demonstrate compliance with substance restrictions.

But I would not publish the stronger claim from the original draft that IEC 63000 itself makes "exemption classification, functional justification and expiry awareness" legally enforceable fields.

The sources reviewed here do not support that formulation.

A safer and more accurate statement is:

Manufacturers should maintain technical documentation and evidence supporting their RoHS conformity assessment, including the information needed to substantiate applicable exemptions.

The specific documentation required will depend on the product and conformity assessment.

What Manufacturers Should Do Before the 2026–2027 Exemption Dates

Step 1: Identify lead-containing materials

Review existing material and component data to identify where lead is present.

Step 2: Identify the applicable exemption

Do not stop at "Series 6" or "7(a)."

Determine whether a specific sub-entry applies.

Step 3: Check the product category

Some revised exemptions have different applicability or expiry dates depending on the RoHS category. (EUR-Lex)

Step 4: Record the expiry date

Store the applicable expiry date against the component/product.

Step 5: Validate supplier evidence

Make sure the supplier information supports the exemption being claimed.

Step 6: Identify approaching expiries

Prioritize products where the exemption expires soonest.

Step 7: Start engineering discussions early

Where an alternative may be necessary, allow time for:

• material selection;
• supplier qualification;
• design changes;
• testing;
• validation;
• production changes.

EU RoHS Lead Exemption Compliance Checklist

The Biggest Mistake Manufacturers Should Avoid

The biggest mistake is treating an exemption as a permanent product attribute.

For example:

Component X → RoHS compliant → Exemption 7(a)

is not enough for a mature exemption-management process.

A better record is:

Component X → Lead-containing solder → 7(a)-III → applicable product category → 31 December 2027 → supporting evidence → expiry monitored

That difference matters because the revised Annex III entries are much more specific than a simple parent-exemption reference.

How Regilient Can Help Manufacturers Manage RoHS Exemptions

The operational challenge is not simply finding the latest RoHS exemption list.

It is keeping the exemption information connected to the products that depend on it.

A manufacturer may have:

• thousands of components;
• hundreds of suppliers;
• multiple BOM revisions;
• different product categories;
• supplier declarations;
• material data;
• exemption records;
• technical documentation.

Regilient can be positioned around managing those relationships in one compliance workflow.

Track

Identify lead-containing components, materials, supplier declarations and applicable exemptions.

Review

Review supplier information and supporting compliance evidence.

Assess

Assess products and components against applicable RoHS restrictions and exemptions.

Continuously Monitor

Track exemption expiry dates and changes affecting products.

Evidence

Maintain the compliance information and supporting documentation needed for your conformity assessment and technical records.

Why Exemption Management Needs to Move Beyond Spreadsheets

A spreadsheet can tell you:

6(c) → 30 June 2027

But it becomes much more useful when it can also answer:

Which products use 6(c)?

Which components rely on it?

Which suppliers provided the supporting evidence?

Which products need engineering review before expiry?

Which declarations need to be refreshed?

That is the difference between tracking an exemption and managing exemption risk.

Final Takeaway

The 2025 EU RoHS amendments do not mean that lead is suddenly prohibited across electronics.

They do mean that manufacturers need to pay much closer attention to which exemption applies to which lead-containing application and how long that exemption remains available.

The revised rules create different expiry dates across Series 6, 7(a) and 7(c), and several exemptions have been divided into more specific sub-entries. (EUR-Lex)

For manufacturers, the practical model is:

Identify lead

→ Classify the application

→ Map the correct exemption/sub-entry

→ Check product-category scope

→ Record expiry

→ Maintain supporting evidence

→ Identify affected products

→ Plan engineering action before expiry

The key question is no longer simply:

"Is this component RoHS compliant?"

It is:

"What exemption supports the lead-containing application, what evidence supports that conclusion, and when does that exemption expire?"

Is Your RoHS Exemption Data Ready for 2026–2027?

If your products contain lead in metals, solder, glass or ceramic components, now is the time to identify which products depend on the revised Annex III exemptions.

Regilient helps manufacturers connect product and component data with supplier declarations, restricted-substance information, exemptions and compliance evidence—so teams can identify affected products and manage exemption expiry before it becomes an engineering or market-access issue.

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