The European Union's RoHS Directive restricts the use of specific hazardous substances inelectrical and electronic equipment (EEE). For manufacturers, RoHS compliance involves more than checking substance concentrations. It also requires understanding when a restricted substance may legally continue to be used under a specific exemption.

RoHS exemptions are application-specific, time-limited, and subject to periodic review.

As exemptions are renewed, narrowed, split into new sub-exemptions, or allowed to expire, manufacturers need to continuously determine whether the exemption supporting a component or product is still valid.

This is where RoHS Pack 23 becomes important.

However, one distinction is essential:

RoHS Pack 23 did not assess exemptions 6(a), 6(b), 6(c), 7(a), and 7(c). Pack 23 covered a separate group of Annex III exemption requests. Exemptions 6(a), 6(b), 6(c), 7(a), and 7(c) were associated with the earlier Pack 22 workstream and have since undergone further regulatory review and amendment.

For manufacturers, the practical lesson is the same:

A RoHS exemption number is not enough. You need to know its exact scope, applicable equipment category, current wording, supporting evidence, and expiry date.

What Is EU RoHS Pack 23?

RoHS Pack 23 refers to a European Commission technical assessment of exemption renewal requests under Annex III of Directive 2011/65/EU, commonly known as the RoHS Directive.

The European Commission uses exemption assessments to determine whether restricted substances should continue to be permitted for specific applications.

Under Article 5 of the RoHS Directive, exemptions can be granted when the required technical and scientific conditions are met.

The assessment considers factors such as:

• Availability of substitutes
• Technical feasibility of substitution
• Reliability of alternatives
• Environmental and health impacts of substitution
• Socioeconomic impacts
• Potential impacts on innovation

RoHS exemptions are therefore not general permissions to use a restricted substance.

They apply only to the specific application and conditions described in the exemption.

For a broader explanation of RoHS scope, restricted substances, documentation and exemptions, see Regilient's RoHS Compliance Scope: Categories, Substances & Exemptions.

Which Exemptions Were Covered by RoHS Pack 23?

Pack 23 focused primarily on the following Annex III exemption areas:

The Pack 23 assessment therefore covered a substantially different set of exemptions from 6(a), 6(b), 6(c), 7(a), and 7(c).

Why does this distinction matter?

Older RoHS articles sometimes group 6(a), 6(b), 6(c), 7(a), and 7(c) together with Pack 23.

That is technically misleading.

Those exemptions were associated with Pack 22, while Pack 23 dealt with exemptions such as 4(f), 8(b), 9(a)-II, 13(a), 13(b), and 15/15(a).

For compliance teams, keeping the exemption history straight matters because the following are separate pieces of information:

Assessment pack → technical recommendation → delegated directive → current legal wording → expiry date → applicable scope

A technical recommendation should therefore not be treated as the final legal status of an exemption.

What Were the Main RoHS Pack 23 Recommendations?

The Pack 23 assessment examined whether existing exemptions remained technically justified and whether their scope or wording needed to change.

Some recommendations proposed extensions with modified wording or narrower scope. Others proposed new sub-exemptions or phase-out arrangements.

Exemption 4(f): Mercury in Certain Discharge Lamps

Pack 23 included exemption 4(f), concerning mercury in certain discharge lamps used for special purposes.

The renewal request was withdrawn because a renewal had already been granted through an earlier European Commission decision.

Compliance implication

Manufacturers should not treat a Pack 23 recommendation as the final legal status of an exemption.

The legally applicable requirement is determined by the RoHS Directive and the relevant delegated acts as they enter into force and become applicable.

Exemptions 8(b) and 8(b)-I: Cadmium in Electrical Contacts

Pack 23 examined exemptions involving cadmium and cadmium compounds in electrical contacts.

The assessment considered applications including:

• Circuit breakers
• Thermal sensing controls
• Thermal motor protectors
• Certain AC switches
• Certain DC switches

The recommendations included narrowing some existing scopes and creating or modifying sub-exemptions rather than simply extending the original wording indefinitely.

Why this matters to manufacturers

A supplier declaration stating:

"RoHS compliant – Exemption 8(b)"

may not provide enough evidence.

A manufacturer needs to determine:

1. What application is covered?
2. What equipment category applies?
3. Is the specific component within the exemption scope?
4. Is the exemption still valid?
5. What evidence supports its use?
6. What happens when the exemption expires or changes scope?

This is why exemption management needs to be connected to the component, BOM, supplier evidence, and product rather than maintained as a standalone spreadsheet.

For more on the limitations of generic supplier declarations, see RoHS Compliance: When Declarations Pass but Testing Fails.

Exemption 9(a)-II: Hexavalent Chromium in Absorption Refrigeration

Pack 23 also assessed exemption 9(a)-II concerning hexavalent chromium used as an anticorrosion agent in the cooling systems of certain absorption refrigerators.

The technical recommendation proposed a narrower continuation, including application to specific equipment categories rather than maintaining the exemption across its previous scope.

This illustrates a recurring pattern in RoHS exemption management:

An exemption can remain relevant while its scope becomes narrower.

Manufacturers therefore need to monitor not only whether an exemption is "renewed," but how its wording and applicability change.

Exemption 13(a): Lead in Glass Used for Optical Applications

Exemption 13(a) concerns lead in glass used for optical applications.

Pack 23 recommended changes to the wording and considered different validity periods depending on equipment category.

This is another reason why compliance teams should avoid treating exemption numbers as permanent classifications.

A component that historically relied on 13(a) may require reassessment when:

• The exemption wording changes
• A new sub-exemption is created
• The product category changes
• The exemption expires
• A new regulatory decision changes the applicable scope

Exemption 13(b): Lead and Cadmium in Filter and Reflectance Glass

Pack 23 also examined the 13(b) series.

The assessment considered applications involving:

• Optical filter glass
• Reflectance standards
• Lead-containing glass
• Cadmium-containing glass

The recommendations included narrower scopes and new sub-exemptions rather than maintaining previous broad wording.

For manufacturers using specialized optical components, this makes application-level exemption mapping particularly important.

Exemptions 15 and 15(a): Lead in Flip-Chip Packages

Pack 23 also examined lead used in flip-chip packages.

The technical assessment did not recommend simply expanding the exemptions because the evidence submitted did not adequately establish that substitution or elimination of lead was technically and scientifically impracticable for the requested applications.

This demonstrates an important principle of RoHS exemptions:

The existence of a historical exemption does not guarantee that it will continue unchanged.

The justification for an exemption must continue to satisfy the requirements of the RoHS exemption process.

What About RoHS Exemptions 6(a), 6(b), 6(c), 7(a), and 7(c)?

This is where many older articles become confusing.

6(a), 6(b), 6(c), 7(a), and 7(c) should not be described as Pack 23 exemptions.

They were associated with the Pack 22 exemption assessment process.

However, they remain highly relevant to manufacturers because the European Commission subsequently amended these exemptions.

Regilient has also published a dedicated EU RoHS 2025 Update: Lead Exemptions 6, 7a, and 7c — New Expiry Dates Now Official, which provides a more detailed breakdown of those changes.

Current RoHS Exemption 6(a): Lead in Steel

RoHS exemption 6(a) covers:

Lead as an alloying element in steel for machining purposes and in galvanised steel containing up to 0.35% lead by weight.

Under the current amendment, the original 6(a) provision expires on:

11 December 2026

The 2025 amendment also introduced more specific sub-exemptions:

• 6(a)-I — lead in steel for machining purposes
• 6(a)-II — lead in batch hot-dip galvanised steel components

Both have later expiry dates of 30 June 2027 for the applicable categories.

Manufacturer takeaway

If a component currently relies on 6(a), do not simply record:

"6(a) – valid."

Instead, determine whether the component fits:

• 6(a)
• 6(a)-I
• 6(a)-II

and whether the applicable expiry date and equipment category match the product.

Current RoHS Exemption 6(b): Lead in Aluminium

RoHS exemption 6(b) covers:

Lead as an alloying element in aluminium containing up to 0.4% lead by weight.

The current original exemption expires on:

11 June 2027

The 2025 amendment also introduced more specific provisions covering aluminium from lead-bearing scrap recycling, machining applications, and certain casting alloys.

The detailed scope and equipment-category conditions should always be checked against the current Annex III wording.

Current RoHS Exemption 6(c): Lead in Copper Alloys

Exemption 6(c) covers:

Copper alloy containing up to 4% lead by weight.

The current expiry date is:

30 June 2027.

For manufacturers using brass, copper alloys, machined components, connectors, terminals, or other metal parts, this makes exemption tracking particularly important.

The compliance question is not simply:

"Does this component contain lead?"

It is:

"Does the lead-containing material fall within the exact RoHS exemption scope applicable to this component and product?"

Current RoHS Exemption 7(a): Lead in High-Melting-Temperature Solder

Exemption 7(a) concerns:

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

The European Commission's 2025 delegated directive reorganized this area into more specific application categories.

The revised structure addresses applications involving areas such as:

• Internal semiconductor interconnections
• Die attach
• First-level solder joints
• Second-level solder joints
• Hermetic sealing
• Certain lamps
• Audio transducers

The original 7(a) provision has a 30 June 2027 expiry, while several new sub-entries have expiry dates extending to 31 December 2027.

Why this matters

A company that previously mapped every high-temperature lead-solder application to 7(a) may now need to determine whether a more specific sub-entry applies.

This is a classic example of why exemption management must capture application-level technical information, not just exemption numbers.

For a current overview of the 2025 restructuring, see Regilient's RoHS 2025 Update: New Lead Exemption Deadlines for 6, 7a & 7c.

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

RoHS exemption 7(c) concerns certain lead-containing electrical and electronic components involving glass and ceramic materials.

The 2025 amendment significantly revised this area.

The revised provisions include additional sub-entries addressing specific applications involving glass, ceramic, capacitors, high-voltage components, semiconductor applications, hermetic sealing, PZT piezoelectric ceramics and positive temperature coefficient ceramics.

Key expiry dates

Important compliance point

The revised 7(c) framework demonstrates why simply recording:

"Component uses exemption 7(c)"

can be insufficient.

The manufacturer needs to identify the specific sub-entry and technical application.

Current RoHS Exemption Snapshot

For a deeper explanation of the 2026 lead-exemption deadlines, see RoHS Lead Exemption Expirations 2026: Manufacturer Guide.

How Does the EU RoHS Exemption Renewal Process Work?

RoHS exemptions are periodically reassessed because technological alternatives can become available over time.

The European Commission evaluates factors including:

• Technical feasibility of alternatives
• Availability of substitutes
• Reliability of substitutes
• Environmental impacts
• Health impacts
• Socioeconomic effects
• Innovation considerations

A renewal application must generally be submitted no later than 18 months before the exemption expires.

The Commission states that a RoHS exemption decision currently takes approximately 18–24 months from the application date.

Where a renewal request has been submitted on time, the existing exemption remains valid while the Commission makes its decision. If renewal is rejected, a transition period may apply.

This creates an important compliance-management requirement:

Manufacturers cannot manage RoHS exemptions using expiry dates alone. They also need to monitor renewal applications, technical assessments, delegated directives, scope changes, and transition periods.

Why RoHS Exemption Tracking Is Difficult

For a complex product, one exemption may apply to dozens or hundreds of components.

The compliance chain can look like this:

Supplier → Material → Component → BOM → Product → Exemption → Expiry → Evidence

A spreadsheet may tell you:

Component 123 → Exemption 7(a)

But an audit-ready compliance system needs to answer much more:

• Which supplier provided the evidence?
• Which material contains the restricted substance?
• What concentration is present?
• Which homogeneous material is affected?
• Which product uses the component?
• Which exemption applies?
• Which sub-exemption applies?
• What equipment category is relevant?
• When does the exemption expire?
• Has the exemption wording changed?
• Is a renewal application pending?
• What evidence supports the exemption?
• Which products need reassessment if the exemption changes?

This is the difference between having compliance data and having traceable compliance intelligence.

For a broader view of how regulations such as RoHS, REACH, Proposition 65 and WFD interact at the product-material level, see Regilient's Comprehensive Guide to Product Material Compliance.

What Evidence Should Manufacturers Maintain for RoHS Exemptions?

A robust RoHS exemption record should ideally connect:

1. Component information

Part number, manufacturer, supplier and product association.

2. Material information

Material composition and, where available, Full Material Disclosure (FMD).

3. Restricted-substance information

Substance identity, concentration and homogeneous-material context.

4. Exemption information

Exact exemption and sub-exemption number.

5. Applicability evidence

Technical information demonstrating why the component falls within the exemption.

6. Validity information

Current expiry date, renewal status and applicable transition provisions.

7. Source documentation

Supplier declarations, test reports, FMDs, technical files and other supporting evidence.

For companies managing structured material declarations, Regilient's IPC-1754 material disclosure guide explains how structured FMD can support transparency across complex supply chains.

This evidence can then be rolled up from:

Component → BOM → Product

Why Supplier Declarations Alone May Not Be Enough

A supplier declaration is an important part of the compliance evidence chain, but a generic statement such as:

"RoHS compliant"

does not necessarily explain:

• Which restricted substances were assessed
• What material data supports the declaration
• Which exemption is being used
• Whether the exemption applies to the specific application
• Whether the declaration reflects the current regulatory requirements
• Whether testing was performed
• When the information was last validated

Regilient's article Supplier Declaration Audits: How Regulators Detect False Compliance explores why manufacturers increasingly need to treat supplier declarations as evidence that must be evaluated rather than simply stored.

How Can Manufacturers Prepare for RoHS Exemption Changes?

A practical RoHS exemption-management process should include five steps.

1. Map exemptions to components

Identify every component that relies on a RoHS exemption.

Do not maintain the exemption only at the product level.

2. Validate the exemption scope

Check whether the actual material and application satisfy the exemption wording.

A supplier declaration alone may not establish applicability.

3. Track expiry dates

Maintain an active exemption register with automated notifications for upcoming expiry dates.

4. Monitor regulatory changes

When an exemption is renewed, split, narrowed, or replaced, identify affected components and products.

5. Maintain an audit-ready evidence trail

Connect supplier declarations, FMDs, test reports, exemption records and product-level compliance decisions.

This creates a defensible compliance record rather than a collection of disconnected documents.

RoHS Exemptions vs RoHS Compliance: What Is the Difference?

An exemption does not mean that a product is generally exempt from RoHS.

Instead, it allows a restricted substance to be used for a specific application under defined conditions.

For example, a component containing lead may still be compliant if the lead-containing application falls within a valid RoHS exemption.

But if the material:

• Falls outside the exemption scope
• Exceeds a permitted concentration
• Is used in an excluded application
• Belongs to an equipment category not covered
• Relies on an expired exemption

the exemption may no longer provide a compliance basis.

For a detailed comparison of the two regulatory frameworks, see RoHS vs REACH: Key Differences and Compliance Overlaps.

How Regilient Helps Manage RoHS Exemptions

Managing hundreds or thousands of components through spreadsheets, email and calendar reminders makes it difficult to maintain a reliable view of exemption status.

Regilient's RoHS compliance software connects supplier data, component screening, exemptions and product-level reporting in one workflow.

With Regilient, compliance teams can:

Screen BOMs and components

Upload BOMs or component lists and identify potential restricted-substance risks.

Automate supplier data collection

Automate supplier outreach, follow-ups and declaration collection instead of manually tracking email responses.

Validate supplier declarations

Review and validate supplier compliance information before associating it with parts and products.

Manage exemptions

Maintain an exemption registry and track applicable expiry dates and regulatory changes.

Roll up compliance status

Connect component-level evidence to BOMs and finished products.

Generate audit-ready documentation

Generate structured reports and product declarations using centralized compliance evidence.

The result is a traceable workflow:

Collect → Validate → Map → Monitor → Report

rather than:

Email → Spreadsheet → Manual Review → Calendar Reminder → Audit Fire Drill

Build a More Traceable RoHS Compliance Process

RoHS exemption management becomes significantly harder as products, suppliers and regulatory requirements grow.

The goal should not simply be to know which exemption number applies.

The goal is to know:

Which restricted substance is present, where it is present, why the exemption applies, what evidence supports it, which products are affected, and what happens when the exemption changes.

That requires connected compliance data.

Regilient helps manufacturers centralize supplier declarations, material information, exemption records, compliance decisions and audit evidence so teams can move from reactive compliance management to continuous, traceable compliance operations.

Managing RoHS exemptions across complex products?

Explore Regilient RoHS Compliance Software or speak with a Regilient compliance expert to see how exemption tracking, supplier evidence collection and product-level RoHS reporting can be managed in one workflow.

Related RoHS Resources

Continue building your RoHS compliance knowledge with:

• RoHS Lead Exemption Expirations 2026: Manufacturer Guide
• EU RoHS 2025 Update: Lead Exemptions 6, 7a, and 7c
• RoHS Compliance Scope: Categories, Substances & Exemptions
• RoHS Compliance: When Declarations Pass but Testing Fails
• Supplier Declaration Audits: How Regulators Detect False Compliance
• Full Material Disclosure: IPC 1752, IPC 1754 & IEC 62474
• RoHS vs REACH: Key Differences and Compliance Overlaps
• Comprehensive Guide to Product Material Compliance

Final Takeaway

RoHS Pack 23 is not simply a list of lead exemptions.

It is part of the EU's continuing process of reviewing whether specific restricted-substance uses remain justified under defined technical and scientific conditions.

For manufacturers, the more important issue is what happens after an exemption is assessed.

Exemptions can be:

Renewed → Narrowed → Split → Reworded → Replaced → Expired

That means compliance teams need more than a static exemption list.

They need a connected view of:

Substance → Material → Component → Supplier → Exemption → Product → Evidence → Expiry

That is the foundation of traceable RoHS compliance.