EU Publishes Revised Lead Exemptions Under RoHS Directive

On November 21, 2025, the European Union published three Commission Delegated Directives that revise several lead-related exemptions under the RoHS 2 Directive (2011/65/EU). These updates have significant implications for manufacturers of electrical and electronic equipment (EEE), who must now review their material declarations and supply chains to ensure continued compliance.

Key Changes to Lead Exemptions

The revisions introduce new expiry dates and tightened conditions for lead used in various material categories.

• Steel Alloys: The exemption for lead as an alloying element in steel for machining purposes (Entry 6(a)-I) is extended until June 30, 2027, with the lead cap remaining at 0.35%. For hot-dip galvanized steel components (Entry 6(a)-II), the exemption is also extended to June 30, 2027, with a lead cap of 0.2%.
• Aluminum Alloys: The exemption for lead in aluminum for machining purposes (Entry 6(b)-II) has been revoked. New applications are banned from December 2025, with a full phase-out required by June 2027. For recycled aluminum (Entry 6(b)-I), the lead cap has been tightened to 0.3%, with expiry dates varying by product category from December 2026 to June 2027.
• Copper Alloys: The exemption for copper alloys containing up to 4% lead by weight is extended until June 30, 2027.
• Other Materials: Exemptions for lead in certain glass and ceramics, as well as in high melting temperature solders, have been refined into more specific subcategories with an expiry date of December 31, 2027.

Implementation Timeline

Member States are required to transpose these new directives into national law by June 30, 2026. The new provisions will become effective on July 1, 2026.

Impact on Manufacturers

These changes will accelerate the industry's transition to lead-free alternatives and directly impact supply chains involved in machining, galvanizing, and electronics manufacturing. The revocation of the exemption for machined aluminum is particularly critical, as it requires companies to actively find and validate substitutes for any new products.

Manufacturers must act now to review their product portfolios and material data to identify any reliance on these revised or revoked exemptions. Proactive substitution planning is essential to avoid market access disruptions and ensure a smooth transition ahead of the new deadlines.

Official Legal Acts

You can access the full text of the Delegated Directives via the links below:

• Lead in Alloys (Steel, Aluminum, Copper): Commission Delegated Directive (EU) 2025/2364
• Lead in High-Melting Temperature Solders: Commission Delegated Directive (EU) 2025/1802
• Lead in Glass and Ceramics: Commission Delegated Directive (EU) 2025/2363