EU RoHS — Lead Exemptions
RoHS exemption 6(b) ends 2026–2027; 6(c) and 7(c)-I await renewal.
RoHS Annex III exemption 6(b) (lead in aluminium) was not renewed in its general form. For product categories 1–7 and 10, sub-exemption 6(b)-I (recycled scrap aluminium) ceases to apply on 11th December 2026 and 6(b)-II (machining aluminium) on 11th June 2027 — fixed dates. Exemptions 6(c) (up to 4% lead by weight in copper alloys) and 7(c)-I (lead in glass or ceramic, other than capacitor dielectric ceramic) were set to expire on 30th June 2027, with narrower new entries 7(c)-V and 7(c)-VI listed to 31st December 2027 — but renewal requests filed in December 2025 have suspended those dates. Under Article 5(5) of the RoHS Directive, an exemption with a timely renewal request stays valid until the European Commission decides on it. Manufacturers relying on 6(b)-I or 6(b)-II in categories 1–7 and 10 need the lead use substituted before the fixed dates; those relying on 6(c) or 7(c)-I need to track a decision that, if negative, starts a 12- to 18-month phase-out.
Last updated 23rd September 2026 · By Vas Parshin and Anabel Amar
Exemption 6(b): lead in aluminium, ending for most product categories
Exemption 6(b) covered lead as an alloying element in aluminium containing up to 0.4% lead by weight, and was not renewed in its general form. Commission Delegated Directive (EU) 2025/2364, published on 21st November 2025 and in force since 11th December 2025, sets the end dates for its sub-exemptions. For product categories 1–7 and 10, 6(b)-I (lead that stems from recycling lead-bearing aluminium scrap) ceases to apply on 11th December 2026, and 6(b)-II (aluminium for machining purposes) on 11th June 2027. For category 9 industrial monitoring and control instruments and category 11, both are listed to 30th June 2027. A new, narrower 6(b)-III covers aluminium casting alloys containing up to 0.3% lead from recycled scrap, also listed to 30th June 2027, and renewal requests filed in December 2025 have suspended some of these 30th June 2027 aluminium dates, 6(b)-III included. A product in categories 1–7 or 10 placed on the EU market after 11th December 2026 or 11th June 2027 that still relies on 6(b)-I or 6(b)-II respectively is non-compliant.
6(c) and 7(c)-I: a 30th June 2027 date that renewal requests have suspended
Exemption 6(c) covers copper alloy containing up to 4% lead by weight — a routine allowance across connectors, contacts and mechanical hardware. Exemption 7(c)-I covers electrical and electronic components containing lead in a glass or ceramic other than dielectric ceramic in capacitors, such as piezoelectronic devices, or in a glass or ceramic matrix compound. Delegated Directives (EU) 2025/2364 and 2025/2363 set both to expire on 30th June 2027 for all categories, and added two narrower entries covering uses of 7(c)-I — 7(c)-V (lead in glass for specific functions such as sealing, bonding, resistive materials and microchannel plates) and 7(c)-VI (lead in PZT piezoelectric and PTC ceramics) — listed to 31st December 2027. The renewal-application deadline for the 30th June 2027 dates was 31st December 2025, and renewal requests for both 6(c) and 7(c)-I were filed in December 2025, the 7(c)-I request also covering 7(c)-V and 7(c)-VI. Under Article 5(5) of the RoHS Directive, an exemption with a timely renewal request stays valid until the Commission decides on it; if renewal is refused, the exemption ends 12 to 18 months after that decision. So 30th June 2027 is no longer the operative date for either exemption, but nor is it an extension: the outcome is still open.
How long a RoHS exemption lasts, and how it ends
Every Annex III entry runs on the rules in Article 5 of the RoHS Directive. A new or renewed exemption is valid for up to 5 years for product categories 1 to 7, 10 and 11, and up to 7 years for categories 8 (medical devices) and 9 (monitoring and control instruments); the period is decided case by case and can be renewed. A renewal application must reach the Commission no later than 18 months before the exemption expires, and the Commission is to decide no later than 6 months before the expiry date unless specific circumstances justify other deadlines. For the 30th June 2027 entries, that target falls at the end of December 2026. The existing exemption stays valid until the decision is taken. If a renewal is rejected, or an exemption is revoked, it expires at the earliest 12 months and at the latest 18 months after the date of the decision.
The Commission also makes a summary of each application public, which is the first place to check before planning around a renewal that someone else may or may not have requested. RoHS evidence sits in the same technical file as the rest of a product's CE marking (see what CE marking costs), and a product also sold in China runs on a separate timetable under China RoHS GB 26572-2025.
Two ways to be compliant when the date arrives — no third option
A manufacturer whose product depends on one of these exemptions has two routes: substitute the restricted lead use with a compliant alternative before the exemption ceases to apply, or rely on a renewal. Renewal applications are made to the European Commission under Article 5 of the RoHS Directive no later than 18 months before the expiry date, with evidence that substituting or eliminating the lead is not yet scientifically or technically practicable; for the 30th June 2027 and 31st December 2027 entries those windows closed on 31st December 2025 and 30th June 2026. Whichever route applies, the product's own RoHS technical documentation, typically prepared to the harmonised standard EN IEC 63000, should hold the evidence supporting any exemption it relies on, and be kept current as those entries change. A product placed on the EU market after its exemption has ceased to apply, without a substitution in place, can no longer legally be sold on the strength of that exemption.
Questions
When does RoHS exemption 6(b) for lead in aluminium alloys expire?
It depends on the sub-exemption and the product category, under Commission Delegated Directive (EU) 2025/2364. For categories 1-7 and 10, 6(b)-I (lead that stems from recycling lead-bearing aluminium scrap, up to 0.4%) ceases to apply on 11th December 2026 and 6(b)-II (aluminium for machining purposes, up to 0.4%) on 11th June 2027; neither was renewed for those categories. For category 9 industrial monitoring and control instruments and category 11, both are listed to 30th June 2027. A new, narrower 6(b)-III covers aluminium casting alloys with up to 0.3% lead from recycled scrap, also listed to 30th June 2027. Renewal requests filed in December 2025 have suspended some of these 30th June 2027 aluminium dates, 6(b)-III included.
When do RoHS exemptions 6(c) and 7(c)-I expire?
Commission Delegated Directives (EU) 2025/2364 and 2025/2363, published 21st November 2025, set both to expire on 30th June 2027 for all categories. Renewal requests for both were then filed in December 2025, within the 18-month window, so under Article 5(5) of the RoHS Directive both remain valid until the Commission decides on them. If a renewal is refused, the exemption ends 12 to 18 months after that decision rather than on 30th June 2027. Exemption 6(c) covers copper alloy containing up to 4% lead by weight; 7(c)-I covers components containing lead in a glass or ceramic other than dielectric ceramic in capacitors.
What about exemptions 7(c)-V and 7(c)-VI?
These are new, more narrowly defined entries added by Delegated Directive (EU) 2025/2363: 7(c)-V covers lead in glass for specific functions such as sealing, bonding, resistive materials and microchannel plates, and 7(c)-VI covers lead in PZT piezoelectric and PTC ceramics. Both were listed to 31st December 2027, but they are included in the December 2025 renewal request for 7(c)-I, so that date is suspended until the Commission decides.
What has to happen before an exemption expires?
A manufacturer relying on a lead exemption has two routes: substitute the restricted lead use, or rely on a renewal. Renewal applications go to the European Commission under Article 5 of the RoHS Directive no later than 18 months before the expiry date: 31st December 2025 for the 30th June 2027 entries and 30th June 2026 for the 31st December 2027 entries, both now passed. An application made in time keeps the exemption valid until the Commission decides. Separately, the product's own RoHS technical documentation, typically prepared to the harmonised standard EN IEC 63000, should hold the evidence supporting any exemption the product relies on.
Does this affect products already on the market?
It affects any product still being placed on the EU market after an exemption ceases to apply, including products already in production. Where the date is fixed, such as 6(b)-I and 6(b)-II for categories 1-7 and 10, a product that still relies on the exemption after that date can no longer be legally placed on the EU market, so the substitution work needs to be finished ahead of it. Where a renewal request is pending, as for 6(c) and 7(c)-I, the exemption stays valid until the Commission decides, and a refusal starts a 12- to 18-month phase-out from the date of that decision.
How long does a RoHS exemption last?
Under Article 5(2) of Directive 2011/65/EU, up to 5 years for product categories 1 to 7, 10 and 11, and up to 7 years for categories 8 (medical devices) and 9 (monitoring and control instruments), decided case by case and renewable. A renewal application is due no later than 18 months before expiry, and the exemption stays valid until the Commission decides. If renewal is rejected, the exemption expires 12 to 18 months after the decision.
Where we fit
This runs on the same clock as CE/UKCA marking and CRA reporting but is a separate technical file — RoHS compliance is proven through material declarations, supplier documentation and technical documentation recording which exemptions a product relies on. We scope which RoHS exemptions a product's bill of materials actually depends on, check them against the fixed 11th December 2026 and 11th June 2027 dates and the pending 6(c) and 7(c)-I renewal decisions, and manage the substitution decision and paperwork against the real deadline.
Contact usSources
- Commission Delegated Directive (EU) 2025/2364, Annex; Greensoft Technology (December 2025 renewal-request status, no primary EU register entry located)
- Commission Delegated Directive (EU) 2025/2364, Annex (6(c)); Commission Delegated Directive (EU) 2025/2363, Annex (7(c)-I, 7(c)-V, 7(c)-VI); Greensoft Technology (December 2025 renewal-request status, no primary EU register entry located)
- Directive 2011/65/EU, Article 5(2), 5(4)(c), 5(5) and 5(6), and Annex I (product categories)
- Directive 2011/65/EU, Article 5(1) & 5(5); Assent (EN IEC 63000 technical-documentation practice)