By Deepa ShettyPublished: 3 min read

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All you need to Know About the Latest EU RoHS Exemption List

Staying abreast of the recent compliance certification directives can be daunting for many manufacturing companies due to the evolving nature of the compliance and regulatory landscape. In case you are wondering what’s new with the EU’s list of Restriction of Certain Harmful Substances (RoHS) in the Hazardous Substances Directives in electrical and electronic equipment that manufacturers or suppliers need to keep note of, we have some news for you!

First, what is the role of the RoHS Directive?

RoHS was first anchored under the EU Directive 2011/65. The RoHS certification confirms if the electrical or electronic products contain safe proportions of substances or materials that are hazardous and difficult to dispose of. The hazardous list of substances includes but is not limited to lead, mercury, hexavalent chromium, and cadmium which have far-reaching impacts on the environment and health of communities that are frequently exposed.

Managing RoHS obligations at a BOM and supplier-declaration level typically requires structured RoHS compliance software rather than spreadsheets, particularly as exemption structures grow more granular with each renewal cycle.

Manufacturers of electronic devices are instructed to use safer and environmental-safe alternatives to these hazardous substances. Manufacturers must document component composition and RoHS assessment evidence in a Technical Documentation File compiled in line with EN IEC 63000:2018, the current harmonised standard for RoHS technical documentation. EN 50581:2012 (and its national adoptions such as DIN EN 50581) was withdrawn from the Official Journal on 18 November 2021 and is no longer acceptable as the basis for RoHS compliance documentation. In 2011, the EU directed manufacturers to use CE-certified products that satisfy the applicable requirements under the community harmonization legislation, upon its installation.

What’s Changed with RoHS Exemption List?

In March 2020, the European Commission revised the EU’s RoHS exemptions, and manufacturers or producers of electrical and electronic supplies are allowed to apply for exemptions under Annexes III and IV for substance restriction limits under certain applications and uses. Annex III exemptions are reviewed on rolling cycles. The Pack 22 assessment, conducted 2022–2024, produced the renewal decisions adopted by the Commission in November 2025 and covered here.

Refer to the status of renewal requests and notices in the downloadable list available on the European Commission’s website. Additionally, you can view the renewal dossiers for exemptions on the COCIR European Trade site. For detailed updates on the restricted substances and new exemptions, download the final report.

What Pack 22 Actually Delivered: The November 2025 Delegated Directives

On 21 November 2025, the European Commission adopted three Commission Delegated Directives — (EU) 2025/1802, 2025/2363, and 2025/2364 — amending Annex III of Directive 2011/65/EU. These entered into force on 11 December 2025, with a transposition deadline of 30 June 2026 and applicability from 1 July 2026.

Key exemption outcomes:

  • 6(a) revoked across all categories; 12-month phase-out for categories 8, 9, 11 (expiry 11 December 2026)
  • 6(a)-I and 6(a)-II created with narrower scope; both initially set to 30 June 2027, currently under renewal review following December 2025 filings
  • 6(b) not renewed for categories 8, 9, 11; expires 11 June 2027
  • 6(b)-I and 6(b)-II not renewed for categories 1–7 and 10; transition periods ending December 2026 and June 2027
  • 6(b)-III created covering categories 1–10 (excluding 9 IMCI and 11), expiring 30 June 2027
  • 6(c) extended to 30 June 2027
  • 7(a) split into application-specific subcategories with parent expiring 30 June 2027; sub-exemptions extend to 31 December 2027 for defined uses only
  • 7(c)-I and 7(c)-II extended, both with December 2025 renewal filings suspending published expiry dates until Commission decision

A new cross-cutting provision restricts these renewed exemptions where EEE is accessible to children and may be placed in the mouth: lead release rate must not exceed 0.05 μg/cm² per hour for at least two years of normal use.

The Directive allows for exemptions from its restrictions, under certain conditions defined in Article 5(1), adapting the Annexes to scientific and technical progress.

Exemptions are granted on a case-by-case basis and are limited in time. They must be reassessed on a regular basis to ensure that they remain necessary and appropriate. When reassessing an exemption, the following factors are taken into account:

  • The availability, practicability, and reliability of substitutes
  • The environmental, health, and consumer safety impacts of substitution
  • The socioeconomic impact of substitution
  • Any potential adverse impacts on innovation Industry stakeholders can apply for exemptions or for the renewal of existing exemptions. An application for renewal of an exemption must be made no later than 18 months before the exemption expires. Each request is evaluated on its own merits, and when appropriate, an exemption is granted.

Assessment studies are conducted to evaluate the impact of substances on human health and the environment. These studies are used to determine whether an exemption is necessary and appropriate. The results of these studies are publicly available and can be accessed by stakeholders and the general public.

Regilient supports you in RoHS compliance specific to your country with a slew of IT solutions and services that design, automate, and speed up the process.

Learn more about Regilient's RoHS compliance software or book a Regilient demo to see how agentic exemption tracking keeps your BOM current against every Pack 22 outcome.

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All you need to Know About the Latest EU RoHS Exemption List

What is the RoHS exemption list and why does the European Commission maintain it?
The RoHS Directive (2011/65/EU) restricts hazardous substances in electrical and electronic equipment, but Annexes III and IV allow manufacturers to apply for exemptions where no viable substitute exists for a specific application. Exemptions are time-limited and must be reassessed periodically, meaning the list is a living document rather than a fixed set of permanent carve-outs. Manufacturers relying on an exemption today should never assume it will remain unchanged indefinitely, since the Commission actively revises, narrows, and revokes exemptions as substitute materials and processes become available.
What criteria does the European Commission use to decide whether to renew a RoHS exemption?
Availability, practicability, and reliability of substitute materials or technologies Environmental, health, and consumer safety impacts of substitution Socioeconomic impact of substituting the restricted substance Any potential adverse effects on innovation Each exemption is assessed individually against these factors, using publicly available assessment studies, rather than renewed as a blanket category.
When must a company apply to renew an existing RoHS exemption?
Renewal applications must be submitted no later than 18 months before the exemption's expiry date under Article 5(1) of the RoHS Directive. Missing this window does not necessarily mean the exemption lapses immediately, since a validly submitted renewal request keeps the exemption in force pending the Commission's decision, but it does mean the company has no formal basis to seek an extension if the original deadline passes unaddressed.
Are all RoHS exemptions being renewed, or are some being phased out entirely?
Both. Some exemptions have not been renewed and are being phased out over a defined transition window once the delegated directive enters into force. Others have been renewed, but frequently split into narrower, application-specific subcategories rather than continued in their original broad form. The overall trend is away from blanket exemption renewals and toward tightly scoped, highly technical exemptions for specific use cases where no substitute currently exists.
What should manufacturers do when a RoHS exemption they rely on is split into subcategories?
Confirm which, if any, of the new subcategories actually covers your specific application, rather than assuming the parent exemption number still applies. A component that was compliant under a broad exemption may fall outside every one of the narrower replacements if its specific use case wasn't accounted for in the split. This requires component-level review, not a directive-level check.
How does Regilient help manufacturers track changes to the RoHS exemption list?
Regilient's agentic sustainability platform maps every restricted-substance component in a BOM to its specific Annex III or IV exemption, monitors Official Journal publications for revocations, renewals, and subcategory splits, and flags components whose exemption basis has changed before the next compliance audit or customer questionnaire surfaces the gap.
What is DSTU EN 50581 and why is it important for Ukraine RoHS?
DSTU EN 50581:2014 is the Ukrainian adoption of the European standard EN 50581 and defines technical documentation requirements to demonstrate RoHS compliance for market access in Ukraine.