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EU releases revised draft of RoHS lead and cadmium exemption clauses

Time：

2026-07-13

The European Commission proposes to revise Annex III and IV of the Directive on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment (RoHS Directive), updating the exemption clauses for lead and cadmium in specific electrical and electronic equipment.

On July 8, 2026, the European Commission proposed amendments to Annexes III and IV of the Directive on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS Directive, 2011/65/EU), updating the exemption clauses for lead and cadmium in specific electrical and electronic equipment.

Scope of Impact

Appendix III: A total of 12 existing exemption entries were revised, covering scenarios such as fluorescent lamp glass, optical glass, discharge lamp phosphors, solder for capacitors, crystal glass, and metal-ceramic-based trimmer potentiometer components.

Appendix IV: Six entries were revised, focusing on adjusting exemption rules for specialized scenarios such as medical devices, industrial monitoring and control instruments (IMCI), and lighting equipment. The revisions cover products including large household appliances, small household appliances, information technology and telecommunications equipment, consumer equipment, lighting equipment, electrical and electronic tools, toys, leisure and sports equipment, medical devices, monitoring and control instruments (including industrial monitoring and control instruments), and automatic dispensers.

Main revised content of Annex III

Optical and filter glass (points 5b, 13a, 13b): The exemption for lead (unintentionally added) in sodium calcium glass used for Class 5 fluorescent lamp glass tubes has been extended for 30 months. The newly added sub clauses (13 (b) - IV to 13 (b) - V) include specific applications such as Class 9 infrared interference filters, with a validity period set at 30 months from the effective date.

Luminaires and phosphors (point 18b): The exemption for lead as an activator in phosphors (such as in tanning lamps or medical phototherapy equipment, including in vitro phototherapy lamps) has been renewed. Depending on the category, these exemptions will expire within 12 to 54 months.

Welding and capacitors (point 24): Point 24 has been updated to clarify the requirements for lead content in ceramic multilayer capacitor solder. It distinguishes between mechanical installation (up to 50% lead) and high melting point processes (down to 85% lead), and sets a transition period of 18 to 54 months.

Other components (points 29, 32, 34): Lead crystal glass, glass melting blocks for laser tubes, and ceramic metal mixture based potentiometers have also received updated validity periods, typically extended to 30 months.

Main revised content of Annex IV

Oxygen Sensor (Key Point 1b): The updated content provides detailed sub points (1 (b) - I to 1 (b) - VI) for lead and cadmium anodes in various oxygen sensors, such as Hershey cells and primary cell sensors. Key medical consumables and specialized industrial sensors have been given longer transition periods, some up to 78 months

Laser (point 9): Cadmium in helium cadmium lasers used for specific applications such as Raman spectrometers is granted a 30 month extension, while the general use period is 12 months.

Imaging and Superconductors (Point 11): The exemption for lead in superconducting circuits and thermal conductors used for MRI and NMR has been clearly set to expire within 12 months from the date of entry.

Compliance Recommendations

This revision mainly refines the applicable scenarios and updates the validity period of lead and cadmium exemptions in Annex III and Annex IV of the EU RoHS. The committee has opened a public opinion solicitation period for the draft directive, with a deadline of August 5, 2026.

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