EU RoHS: Updates on Lead Exemptions in Various Applications

In November 2025, the European Union (EU) published important updates to the RoHS Directive (2011/65/EU) concerning exemptions for the use of lead in various applications. The new amendments—Directives EU 2025/2363, 2025/2364, and 2025/1802—address lead in metal alloys, high-melting-point solders, and glass or ceramic components used in electrical and electronic equipment.

These amendments become effective 20 days after publication, on 11 December 2025, and update the exemptions listed in Annex III, points 6 and 7 of the RoHS directive. Manufacturers, importers, and exporters must review these changes to ensure compliance.

Key Updates for Metal Alloys (Point 6, Annex III)

• Lead in steel alloys for machining and galvanised steel (≤0.35% lead) – expires 11 Dec 2026 / 30 Jun 2027.

• Lead in aluminium alloys, including recycled aluminium (≤0.4% lead) – expires 11 Dec 2026 to 30 Jun 2027 depending on category.

• Lead in copper alloys (≤4% lead) – expires 30 Jun 2027.

Key Updates for Solders and Ceramics (Point 7, Annex III)

• High-melting-point solders (≥85% lead) for die attach, first- and second-level solder joints, hermetic sealing, lamps, and audio transducers – expires 30 Jun 2027 to 31 Dec 2027.

• Glass and ceramic components containing lead for insulation, bonding, PZT or PTC ceramics, and dielectric capacitors – expires 30 Jun 2027 to 31 Dec 2027.

These exemptions clarify the permissible lead content in specific applications, helping businesses maintain RoHS compliance while using certain lead-containing materials in electrical and electronic equipment.