RoHS: European Commission Proposes Updates to Key RoHS Lead Exemptions

April 29, 2025

In early January 2025, the European Commission notified the World Trade Organization (WTO) about three draft Delegated Directives proposing amendments to Annex III of the Restriction of Hazardous Substances (RoHS) Directive (2011/65/EU). These drafts address widely used temporary exemptions for lead in specific applications within electrical and electronic equipment (EEE). The public consultation period for these drafts concluded on February 10, 2025. 
The purpose of these amendments is to adapt the RoHS exemptions list to scientific and technical progress, as required by the Directive. While RoHS restricts lead to 0.1% by weight in homogeneous materials in EEE, Annex III allows temporary exemptions where substitution is currently scientifically or technically impracticable, or where the reliability of substitutes is not ensured, provided environmental and health protection is not weakened compared to REACH regulations.
 

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