European Commission publishes draft delegated directive restructuring Annex III exemption 7(a) (lead in high-melting-temperature solders) into sub-entries

The European Commission issued a draft delegated directive (Commission document dated 8 Sep 2025) proposing to amend Directive 2011/65/EU by restructuring Annex III exemption 7(a) (lead in high-melting-temperature solders) into multiple sub-entries (e.g., 7(a)-I to 7(a)-VII) tied to specific application areas. For compliance teams, this signals a forthcoming change in how products relying on exemption 7(a) must be mapped and justified (more granular applicability conditions), and may affect exemption-renewal dossier strategy and evidence needs. The draft also reiterates procedural expectations (e.g., renewal applications due no later than 18 months before expiry; exemptions generally remain valid while a timely renewal is pending).