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RoHS Annex III Lead Exemptions: Changes and Renewals
RoHS limits lead to 0.1% by weight in each homogeneous material. Annex III of Directive 2011/65/EU lists the applications where lead is still allowed because reliable substitutes do not yet exist - mainly lead as an alloying element in steel, aluminum and copper, lead in high-melting-temperature solders, and lead in glass and ceramics. Every exemption carries an expiry date. Industry can apply for renewal no later than 18 months before expiry, and an exemption stays valid while a renewal application filed on time is being decided.
Three Commission Delegated Directives published in the Official Journal on November 21, 2025 rewrote the main lead exemptions. EU Member States had to transpose them by June 30, 2026, and they apply from July 1, 2026. Norway and the other EEA states have taken the same changes into national law.
See also RoHS 3 (EU 2015/863) for Category 8 and 9 exemptions, which fall under both Annex III and Annex IV.
Lead as an alloying element - Delegated Directive (EU) 2025/2364
| Entry | Application | Categories | Expires |
|---|---|---|---|
| 6(a) | Lead in machining steel and galvanized steel, up to 0.35% by weight | All | December 11, 2026 |
| 6(a)-I | Lead in machining steel, up to 0.35% by weight | All | June 30, 2027 |
| 6(a)-II | Lead in batch hot-dip galvanized steel components, up to 0.2% by weight | All | June 30, 2027 |
| 6(b) | Lead in aluminum, up to 0.4% by weight | All | June 11, 2027 |
| 6(b)-I | Lead in aluminum up to 0.4% from recycled lead-bearing aluminum scrap | 1-7 and 10 | December 11, 2026 |
| 6(b)-I | Same as above | 9 (industrial monitoring and control instruments) and 11 | June 30, 2027 |
| 6(b)-II | Lead in machining aluminum, up to 0.4% by weight | 1-7 and 10 | June 11, 2027 |
| 6(b)-II | Same as above | 9 (industrial monitoring and control instruments) and 11 | June 30, 2027 |
| 6(b)-III | Lead in aluminum casting alloys up to 0.3% from recycled lead-bearing scrap | 1-8, 9 (except industrial monitoring and control instruments) and 10 | June 30, 2027 |
| 6(c) | Copper alloy containing up to 4% lead by weight | All | June 30, 2027 |
High-melting-temperature solders - Delegated Directive (EU) 2025/1802
High-melting-temperature solders are lead-based alloys containing 85% or more lead by weight. The single 7(a) entry was split into seven application-specific entries. All apply to all categories except applications covered by entry 24.
| Entry | Application | Expires |
|---|---|---|
| 7(a) | General entry for high-melting-temperature solders | June 30, 2027 |
| 7(a)-I | Semiconductor die attach and internal interconnections above set current, voltage or die-size thresholds | December 31, 2027 |
| 7(a)-II | Integral die-attach connections meeting set thermal and electrical conductivity limits | December 31, 2027 |
| 7(a)-III | First-level solder joints that do not reflow during later soldering | December 31, 2027 |
| 7(a)-IV | Second-level joints for ceramic BGA solder balls and high-temperature plastic overmolding | December 31, 2027 |
| 7(a)-V | Hermetic sealing between ceramic packages or plugs and metal cases | December 31, 2027 |
| 7(a)-VI | Electrical connections in infrared heating reflector, high-intensity discharge and oven lamps | December 31, 2027 |
| 7(a)-VII | Audio transducers with peak operating temperatures above 200 C | December 31, 2027 |
Lead in glass and ceramics - Delegated Directive (EU) 2025/2363
| Entry | Application | Expires |
|---|---|---|
| 7(c)-I | Lead in glass or ceramic other than dielectric ceramic in capacitors, such as piezoelectronic devices | June 30, 2027 |
| 7(c)-II | Lead in dielectric ceramic in capacitors rated 125 V AC or 250 V DC or higher | December 31, 2027 |
The same directive adds two new, narrower entries, 7(c)-V and 7(c)-VI, for specific glass and ceramic uses. Check the Annex III text in EUR-Lex for their exact wording and dates.
Renewal applications
Renewal applications for several of these entries were filed in December 2025. Under Article 5 of the RoHS Directive, an exemption stays valid past its listed expiry date until the Commission decides on a renewal application submitted on time. Supplier declarations should record both the listed expiry date and whether a renewal is pending.
Other lead exemptions to track
- Entry 46, recovered PVC - Delegated Directive (EU) 2024/232 allows lead in recovered rigid PVC used in electrical and electronic windows and doors until May 28, 2028. From May 28, 2026, that PVC may only go into specified applications, and articles with 0.1% or more lead must be marked.
- Draft exemption package - a Commission draft delegated directive published July 8, 2026 renews or revises more than 20 Annex III and Annex IV entries, including lead in optical and filter glass (13(a), 13(b)), lead in ceramic multilayer capacitor solder (24(a)), crystal glass (29) and cermet trimmer potentiometers (34). Proposed validity runs 30 to 78 months from entry into force. It is not yet adopted.
Where to check for changes
- EUR-Lex - the consolidated text of Directive 2011/65/EU and each delegated directive
- European Commission "Have your say" portal - draft exemption decisions open for feedback
- Oeko-Institut RoHS evaluation pages - technical assessments behind each renewal