RoHS Exemptions List Updated in CDX — IPC-1752A Amendment 3 (February 2026)

February 26, 2026

We are pleased to announce that the CDX Compliance Data eXchange (CDX) platform has been updated to reflect the latest revision of the IPC-1752A Appendices B, C, D, E, and F, incorporating Amendment 3 with the most current EU RoHS exemption data.

Why does this matter for your declarations?
Suppliers and manufacturers using CDX to submit IPC-1752A declarations should review their existing declarations to ensure they reference valid and current exemption IDs. Declarations for new products placed on the EU market must be aligned with the exemptions in Table B2 as updated by Amendment 3. Components relying on exemptions that have recently expired or that have been restructured into new sub-entries may require updated declarations before the next submission cycle.
It is worth noting that while the EU Delegated Directives underpinning these changes were published throughout 2025, the IPC-1752A Appendices formally reflecting those updates were released by the IPC working group only in February 2026. This means a period of several months passed between the entry into force of regulatory changes at the EU level and their incorporation into the IPC-1752A standard. The CDX platform has been updated in line with the IPC publication date. We encourage users to review any declarations submitted during this interim period against the updated exemption tables.

What has changed?
The IPC-1752A working group has published an updated set of Appendices that align the exemption tables with the latest EU Delegated Directives issued in 2025. The most significant changes are presented in the table below.

Updated & New Exemptions

Exemption ID	Full Description	Change Type	Validity / Expiry	Applicable Categories
6(a)	Lead as an alloying element in steel for machining purposes and in galvanized steel containing up to 0.35% lead by weight	Partially expired; still valid for Cat. 8, 9, 11	Expires 11 Dec 2026 (Cat. 8, 9, 11)	Cat. 8, 9, 11 only (Cat. 1–7, 10 expired 1 July 2019)
6(a)-I	Lead as an alloying element in steel for machining purposes (≤0.35%) and in batch hot-dip galvanised steel components (≤0.2%)*	New sub-entry replacing 6(a) for all categories	Expires 30 June 2027	All
6(a)-II	Lead as an alloying element in batch hot-dip galvanised steel components (≤0.2%)*	New sub-entry	Expires 30 June 2027	All
6(b)	Lead as an alloying element in aluminium containing up to 0.4% lead by weight	Partially expired; still valid for Cat. 8, 9, 11	Expires 11 June 2027 (Cat. 8, 9, 11)	Cat. 8, 9, 11 only (Cat. 1–7, 10 expired 1 July 2019)
6(b)-I	Lead as an alloying element in aluminium (≤0.4%) provided it stems from lead-bearing aluminium scrap recycling*	New sub-entry	Expires 11 Dec 2026 (Cat. 1–7, 10); 30 June 2027 (Cat. 9 industrial, 11)	Cat. 1–7, 10; Cat. 9 ind. & 11
6(b)-II	Lead as an alloying element in aluminium for machining purposes (≤0.4%)*	New sub-entry	Expires 11 June 2027 (Cat. 1–7, 10); 30 June 2027 (Cat. 9 ind., 11)	Cat. 1–7, 10; Cat. 9 ind. & 11
6(b)-III	Lead as an alloying element in aluminium casting alloys (≤0.3%) from lead-bearing aluminium scrap recycling*	New sub-entry	Expires 30 June 2027	Cat. 1–8, 9 (excl. industrial M&C), 10
6(c)	Lead in copper alloy containing up to 4% by weight*	Updated validity	Expires 30 June 2027	All
7(a)	Lead in high melting temperature type solders (≥85% lead by weight) — base entry excluding sub-entries 7(a)-I to VII and point 24	Updated validity	Expires 30 June 2027	All (except applications under point 24)
7(a)-I to 7(a)-VII	Various specific applications of high melting solders (≥85%) including semiconductor die attach, solder joints, hermetic sealing, lamps, and audio transducers	New sub-entries	Expires 31 Dec 2027	All (except point 24)
7(c)-I	Components containing lead in glass or ceramic (excluding dielectric ceramic in capacitors)	Updated validity	Expires 30 June 2027	All
7(c)-II	Lead in dielectric ceramic in capacitors ≥125V AC or ≥250V DC	Updated validity	Expires 31 Dec 2027	All (except 7(c)-I or 7(c)-IV)
7(c)-V	Lead in glass/glass matrix compounds for high-voltage protection, hermetic sealing, bonding, resistive material, and modified glass surfaces	New sub-entry	Expires 31 Dec 2027	All
7(c)-VI	Lead in ceramic components including piezoelectric PZT ceramics and PTC ceramics	New sub-entry	Expires 31 Dec 2027	All (except 7(c)-II, 7(c)-III, 7(c)-IV, Annex IV point 14)
39(b)	Cadmium in downshifting semiconductor nanocrystal quantum dots deposited on LED chips for display/projection; ≤5 µg Cd/mm²; max 1 mg per device	New sub-entry replacing 39(a)	Expires 31 Dec 2027	All
* Footnote: The exemption shall not cover EEE for supply to the general public where the EEE or accessible part may be placed in the mouth by children. The exemption applies only if the rate of lead release does not exceed 0.05 µg/cm² per hour (0.05 µg/g/h). For coated articles, the coating must ensure compliance for at least two years of normal or foreseeable use. An EEE part is considered placeable in the mouth if smaller than 5 cm in one dimension or has a detachable/protruding part of that size.

Expired Exemptions
Exemption ID	Full Description	Expiry Date	Notes
39(a)	Cadmium selenide in downshifting cadmium-based semiconductor nanocrystal quantum dots for use in display lighting applications (<0.2 µg Cd per mm² of display screen area)	21 November 2025	Replaced by 39(b); please note the scope differs as 39(b) covers LED chip direct deposition only
1(f)-II	Mercury in single-capped compact fluorescent lamps (≤5 mg per burner) for special purposes	24 February 2025
3(a) / 3(b) / 3(c)	Mercury in CCFL and EEFL lamps for special purposes (short ≤500mm / medium 500–1500mm / long >1500mm)	24 February 2025
2(b)3	Mercury in non-linear tri-band phosphor lamps with tube diameter >17mm (e.g. T9); 10 mg limit	24 February 2025	The 15 mg limit for this exemption had already expired on 24 February 2023