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).
A European Commission delegated directive package (Commission document dated 8 Sep 2025) indicates an amendment to Directive 2011/65/EU (RoHS) Annex III regarding exemption 7(a) for lead in high-melting-temperature solders. The package describes revising the wording and splitting exemption 7(a) into multiple more specific sub-entries (described as 7(a)-I through 7(a)-VII) to better define scope by application area and enable more targeted future assessments/renewals. Compliance teams relying on Annex III 7(a) should be prepared to map current uses to the new sub-entry structure and reassess exemption-claim documentation once the delegated directive is finalized/published in the Official Journal.
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.
The European Commission’s RoHS implementation page reiterates key procedural guidance relevant to managing RoHS exemptions, including: renewal applications must be submitted no later than 18 months before an exemption expires; typical decision-making timelines (18–24 months); continued validity of an exemption when a timely renewal request is pending; and typical transition periods (12–18 months) when a renewal is rejected. These points impact compliance planning for products relying on Annex III/IV exemptions.
The European Commission’s RoHS implementation page consolidates operational guidance on the Article 5 exemptions process, including: exemption renewal applications must be submitted no later than 18 months before expiry; exemptions remain valid if a renewal request is timely until the Commission takes a decision; if renewal is rejected, a 12–18 month transition period typically applies; and decisions generally take 18–24 months from application. The page also records recent stakeholder consultation activity (e.g., “Pack 28” consultation window). Compliance teams can use this for planning exemption renewal submissions, managing continued market access during pending decisions, and scheduling redesign/substitution timelines when renewals may be denied.
The European Commission initiated an infringement procedure (letter of formal notice) against Cyprus for not transposing Commission Delegated Directive (EU) 2024/1416, which amends the RoHS Directive (2011/65/EU) by narrowing the scope of a cadmium-related exemption for certain LED applications due to technical progress. This signals heightened enforcement attention on Member State transposition of RoHS delegated directives, which can affect consistent EU market access and national enforcement posture.
A WTO TBT notification indicates the EU notified a draft Commission Delegated Directive proposing renewal/continuation of RoHS Annex III exemptions for lead as an alloying element in steel, aluminium, and copper. The notification includes a formal public comment deadline. Compliance teams relying on these lead-alloy exemptions should monitor the final delegated directive publication and confirm any revised scope/conditions/validity dates once adopted.
The European Commission opened infringement procedures against Cyprus by sending a letter of formal notice for failing to transpose into national legislation Commission Delegated Directive (EU) 2024/1416, which amends the RoHS Directive (2011/65/EU) regarding an exemption for cadmium in downshifting quantum dots directly deposited on LED semiconductor chips. Member States are required to transpose delegated directives within specified timeframes; non-compliance triggers enforcement action. This signals the Commission's active monitoring of RoHS transposition across Member States.
The European Commission’s RoHS Directive implementation page provides authoritative procedural guidance on exemption renewals under Directive 2011/65/EU. It explains that timely renewal requests keep exemptions valid until a Commission decision is taken, and that rejected renewals typically include a 12–18 month transition period before expiry. It also notes expected decision timelines and links to the exemptions list and exemption application guidance materials. Compliance teams should use this page to plan exemption renewal submissions (18 months before expiry) and manage transition planning when exemptions are rejected or revised.
The European Commission opened infringement procedures (letters of formal notice) against Portugal and Slovakia for failure to communicate national transposition measures for Commission Delegated Directive (EU) 2024/232 by the required deadline stated in the research text (31 July 2024). The delegated directive amends RoHS to enable certain uses of recovered rigid PVC in plastic profiles for electrical/electronic windows and doors under specified conditions (including cadmium and lead concentration limits and marking/traceability requirements as described in the research text). This enforcement action is relevant for companies relying on Member State implementation of the exemption and indicates increased Commission scrutiny on timely transposition of RoHS delegated directives.
The European Commission adopted an infringements package that includes letters of formal notice to Portugal and Slovakia for failing to transpose Commission Delegated Directive (EU) 2024/232 amending Directive 2011/65/EU (RoHS). The delegated directive introduces a RoHS exemption for certain applications involving cadmium and lead in plastic profiles in electrical and electronic windows and doors containing recovered rigid PVC. Compliance teams placing such products on the EU market should monitor national transposition/implementation in the cited Member States, as lack of transposition can create market-access uncertainty for products relying on the exemption despite EU-level adoption.
The European Commission published a proposal (COM(2023) 781; 2023/0454 (COD)) to amend Directive 2011/65/EU (RoHS) to re-attribute certain scientific and technical assessment tasks (notably around restriction review processes and the exemptions process) to the European Chemicals Agency (ECHA), consistent with the EU “one substance, one assessment” policy direction. This is a proposed legislative change (not yet in force) that could affect how future RoHS substance restrictions and exemption evaluations are conducted, potentially impacting evidence expectations, process transparency, and timelines once adopted.
The European Commission published a legislative proposal (COM(2023) 781) to amend Directive 2011/65/EU (RoHS) to re-attribute scientific and technical tasks (notably supporting processes under Article 5 exemptions and Article 6 review/amendment of restricted substances) to the European Chemicals Agency (ECHA). If adopted, this would change how RoHS exemptions and potential restriction updates are scientifically assessed and managed, with implications for exemption application strategy, evidence requirements, and monitoring of RoHS restriction/exemption decision-making workflows.
European Commission materials indicate the RoHS review was finalised and a targeted amendment was proposed on 7 Dec 2023. The proposal (COM(2023) 781) would amend Directive 2011/65/EU to re-attribute scientific and technical assessment tasks (e.g., supporting restricted substances review and exemptions work) to the European Chemicals Agency (ECHA) under the EU 'one substance, one assessment' approach. For RoHS compliance teams, this is a forward-looking governance/process change that could affect how future Annex II substance restrictions and Annex III/IV exemptions are assessed (evidence expectations, transparency, timelines, and stakeholder engagement), even though it does not itself add substances or change exemption text yet.
A Commission Delegated Directive document (C(2023) 7088 final) in the Commission transparency register proposes adding a RoHS exemption covering cadmium and lead in plastic profiles (recovered rigid PVC) used in certain electrical and electronic windows and doors (referenced as category 11 EEE in the research notes). The draft text referenced in the research indicates an expiry date (reported as 28 May 2028). Compliance teams using recovered PVC profiles should monitor adoption/publication and confirm any concentration limits, conditions, and documentation needs in the final legal text.