Commission Delegated Directive (EU) 2025/2363 has restructured the RoHS Annex III exemption for lead in glass and ceramic components. The original broad exemption Entry 7(c)-I has been split into two separate entries: 7(c)-V for lead in glass applications and 7(c)-VI for lead in ceramic applications. This restructuring provides more precise scope definitions for each exemption category, improving clarity for compliance determinations. Manufacturers using lead in glass or ceramic components must verify which specific sub-exemption applies to their products.
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.
Commission Delegated Directive (EU) 2025/2363 amends Annex III of Directive 2011/65/EU (RoHS) to renew the exemption for lead in glass and ceramic components. The exemption covers point 7(c)-I of Annex III, which includes components containing lead in glass or ceramic (other than dielectric ceramic in capacitors), such as piezoelectronic devices or items in a glass or ceramic matrix. Manufacturers using these materials must ensure continued compliance with exemption conditions and monitor for any scope or expiration changes.
Commission Delegated Directive (EU) 2025/1802, adopted on 8 September 2025 and published on 21 November 2025, renews and amends the RoHS exemption for lead in high melting temperature solders (lead-based alloys containing 85% or more lead by weight). The exemption renewal is recorded in Annex III of Directive 2011/65/EU and applies to electrical and electronic equipment placed on the EU market. Manufacturers using high-temperature lead-based solder alloys should verify their compliance status against the updated exemption terms and any new expiry dates.
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.
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 Commission Delegated Directive document (C(2025) 5939 final) in the Commission transparency register describes an amendment to Directive 2011/65/EU (RoHS) Annex III concerning the exemption for lead in high-melting-temperature solders (historically exemption 7(a)). The document indicates a restructuring approach that splits the exemption into multiple sub-entries (I–VII) to clarify scope and support more granular assessment/management. Compliance teams using high-Pb high-melting solders should prepare for exemption applicability to be tied to specific sub-entry conditions once the measure is finalized/published in the Official Journal.
A European Commission transparency-register document (dated 8 September 2025) describes a delegated directive intended to amend Directive 2011/65/EU (RoHS) Annex III exemption 7(a) for lead in high-melting-temperature solders. The document indicates the exemption would be restructured into multiple sub-entries (7(a)-I to 7(a)-VII) to better define scope and uses (e.g., different application areas such as interconnections, die attach, sealing and certain lamps/components). Compliance teams relying on exemption 7(a) should monitor the final adopted delegated directive/Official Journal publication and align product documentation to the revised exemption sub-scope once confirmed.
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.
Commission Delegated Directive (EU) 2025/2363, dated 8 September 2025, amends Annex III of Directive 2011/65/EU regarding exemptions for lead in glass or ceramic components. Manufacturers using lead in glass or ceramic components in electrical and electronic equipment should review the updated exemption scope, validity periods, and any new sub-entry structuring to ensure continued compliance.
Commission Delegated Directive (EU) 2025/1802 amends RoHS Directive 2011/65/EU regarding exemptions for lead in high melting temperature type solders (lead-based alloys containing 85% by weight or more lead). This exemption update affects manufacturers using these specialized solders in electrical and electronic equipment placed on the EU market. Compliance teams must verify whether their solder applications qualify under the updated exemption terms and track any associated expiry dates.
Commission Delegated Directive (EU) 2025/2364 of 8 September 2025 amends Directive 2011/65/EU regarding an exemption for lead as an alloying element in steel, aluminium and copper used in the manufacture of electrical and electronic equipment (EEE). This delegated directive updates the RoHS exemption framework for lead-containing alloys, which manufacturers rely on for certain applications where substitution is not yet technically feasible. Companies using these materials should review the updated exemption terms and expiry dates.
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 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 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.