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

A European Commission draft delegated directive (C(2025) 5939 final, dated 8 Sep 2025) proposes amending Directive 2011/65/EU (RoHS) Annex III exemption 7(a) for “lead in high melting temperature type solders” (lead-based alloys containing ≥85% Pb by weight). The draft would split the current broad exemption into multiple, more specific sub-entries (7(a)-I to 7(a)-VII) aligned to defined application areas (e.g., internal interconnections, die attach, first-/second-level solder joints, hermetic sealing, certain lamps, audio transducers). For compliance teams, this signals a likely future need to re-map product uses currently claimed under legacy 7(a) to the correct new sub-entry and to track potentially different validity/expiry and renewal evidence expectations per sub-entry once adopted/published.