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RoHS Annex III Lead Exemptions 2025-2027

Detailed overview of the changes and new additions to the RoHS Annex III lead exemptions for the period of 2025-2027, based on current regulatory developments. Annex III of the EU RoHS Directive (2011/65/EU) lists exemptions allowing the use of restricted substances like lead in specific applications where substitutes are not yet feasible. These exemptions are subject to expiration, renewal, or amendment, and the 2025-2027 timeframe includes several notable updates for lead-related exemptions.

Lead is restricted under RoHS to a maximum concentration of 0.1% by weight in homogeneous materials, but exemptions in Annex III permit its use in specific cases (e.g., solders, alloys, or glass). Updates to these exemptions stem from technical assessments, industry applications for renewal, and the European Commission's review process under Article 5. Exemptions can expire unless renewed, and new ones may be added based on scientific justification.

See also Category 8 exemptions and deadlines, which fall under both Annex III and Annex IV.


Changes to Existing Lead Exemptions


  1. Exemption 7(a): Lead in High Melting Temperature Solders

    • Description: Lead in high melting temperature type solders (e.g., lead-based alloys containing 85% by weight or more lead).
    • Categories Affected: Applies to Categories 1-7 and 10 (e.g., consumer electronics, IT equipment, industrial tools).
    • Status as of 2025: This exemption has been under review for years due to efforts to find lead-free alternatives. The current expiration date for Categories 1-7 and 10 was extended previously to July 21, 2021, but renewal applications have kept it active with staggered deadlines.
    • Change for 2025-2027:
      • For Categories 1-7 and 10, the exemption is expected to face a critical review with a potential expiration in 2026 unless renewed. The exact date depends on the outcome of renewal applications submitted by industry (typically 18 months prior to expiration). As of March 2025, no final decision has been published, but a delegated act could confirm this by mid-2025.
      • For Category 11 (other electrical and electronic equipment), the exemption remains valid until July 21, 2024, with a possible extension into 2025-2026 under review.
    • Implication: Manufacturers must prepare for potential phase-out, as lead-free high-temperature solders (e.g., bismuth-based) are still less reliable in some applications.

  2. Exemption 7(b): Lead in Solders for Servers, Storage, and Network Infrastructure

    • Description: Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit flip-chip packages, and for servers, storage, and network infrastructure equipment.
    • Categories Affected: Primarily Category 3 (IT and telecom equipment) and Category 11.
    • Status as of 2025: Previously extended to July 21, 2021, for Categories 1-7 and 10, with Category 11 extending to July 21, 2024.
    • Change for 2025-2027:
      • Renewal applications are under evaluation. If approved, the exemption could extend to 2026 or 2027 for Category 11, with a decision expected by late 2025 or early 2026.
      • For specific uses in flip-chip packages, this exemption may be split or refined to reflect technological advancements in lead-free soldering.
    • Implication: IT equipment manufacturers should monitor updates, as server and storage applications remain dependent on lead solders.

  3. Exemption 7(c)-I: Lead in Glass or Ceramic Materials

    • Description: Lead in glass or ceramic other than dielectric ceramic in capacitors (e.g., piezoelectronic devices) or in ceramic matrix compounds.
    • Categories Affected: Applies across all categories (1-11).
    • Status as of 2025: Extended previously to July 21, 2021, for Categories 1-7 and 10, and July 21, 2024, for Category 11, with ongoing renewals.
    • Change for 2025-2027:
      • Likely to remain valid through 2026 for Categories 1-7 and 10, pending renewal decisions expected by mid-2025.
      • For Category 11, expiration could occur in 2026 unless extended further.
    • Implication: Widely used in electronic components; renewal is probable due to limited substitutes, but timelines will clarify by 2025.

  4. Exemption 7(c)-II: Lead in Dielectric Ceramic Capacitors

    • Description: Lead in dielectric ceramic in capacitors for a rated voltage of 125 V AC or 250 V DC or higher.
    • Categories Affected: Applies to Categories 1-7 and 10.
    • Status as of 2025: Extended to July 21, 2021, with renewals keeping it active.
    • Change for 2025-2027:
      • Under review, with a potential expiration in 2026 unless renewed. A decision could come in 2025 based on applications submitted by 2024.
    • Implication: Critical for high-voltage applications; renewal likelihood is high, but lead-free ceramics are advancing.

  5. Exemption 15: Lead in Solders for Filters and Transformers

    • Description: Lead in solders to attach electrical connections to temperature measurement filters or transformers in high-power transducers.
    • Categories Affected: Categories 8 and 9 (medical devices and industrial monitoring equipment).
    • Status as of 2025: Extended to July 21, 2024, for Categories 8 and 9.
    • Change for 2025-2027:
      • Renewal is under consideration, with a possible extension to 2026 or 2027. A decision is expected by late 2025.
    • Implication: Niche but essential for specific industrial uses; renewal depends on substitute availability.

New Additions to Lead Exemptions in Annex III


  1. Lead in Recycled Rigid PVC (New Exemption)

    • Description: Lead in recovered rigid PVC used in profiles and sheets for electrical and electronic windows and doors, with a tolerance of up to 0.1% lead by weight where it occurs as an impurity from recycling.
    • Categories Affected: Primarily Category 2 (large household appliances) and Category 11.
    • Status as of 2025: Introduced via a delegated act (likely in 2023-2024) to support circular economy goals, this exemption is active as of March 2025.
    • Details for 2025-2027:
      • Valid until May 28, 2028, but its implementation will peak in 2025-2027 as manufacturers adapt supply chains.
      • Requires labeling to indicate lead presence if above 0.1% in homogeneous materials.
    • Implication: Encourages recycling but adds compliance complexity for PVC-based EEE manufacturers.

Summary of Key Dates and Trends

  • 2025: Decisions on renewals for 7(a), 7(b), 7(c)-I, 7(c)-II, and 15 expected mid-year; new PVC exemption fully in effect.
  • 2026: Potential expiration of 7(a), 7(b), 7(c)-I, and 7(c)-II for certain categories unless renewed.
  • 2027: Possible extension deadlines for Category 11 exemptions; PVC exemption continues.

Considerations

  • Renewal Process: Exemptions require industry applications (submitted 18 months before expiration) and evaluations by the European Commission, often with input from consultants like the Öko-Institut. Final delegated acts in 2025-2026 will confirm exact dates.
  • Technical Progress: The push for lead-free alternatives (e.g., tin-silver-copper solders, bismuth alloys) may lead to narrower exemptions or stricter conditions.
  • Monitoring: Check the EU's EUR-Lex database or UK OPSS updates for delegated acts published in 2025-2027.

NOTE: Regulatory timelines may shift, so staying updated with official publications is essential for compliance.