Commission Delegated Directive (EU) 2025/2364 amends RoHS Annex III lead alloy exemptions

Commission Delegated Directive (EU) 2025/2364 restructures and renews RoHS Annex III exemptions 6(a), 6(b), and 6(c) for lead as an alloying element in steel, aluminium, and copper. Key changes include: exemption 6(a) for lead in steel is not renewed and expires December 11, 2026; new sub-exemptions 6(a)-I and 6(a)-II are created for specific applications expiring June 30, 2027; exemption 6(b) for lead in aluminium is partially renewed with new subcategories; exemption 6(c) for lead in copper alloys is renewed until June 30, 2027. Manufacturers must review product portfolios to identify items relying on expiring exemptions.