Services: Electrical testing and certification, environmental or chemical testing

language
- English
- 中文

400-9269-886

NEWS CENTER

Industry News

Company News

Knowledge

The EU has adopted the revised draft of RoHS lead exemption, which has these impacts on electronic and electrical enterprises!

Time：

2025-09-11

The EU has adopted three revised drafts on lead exemptions under the RoHS Directive (2011/65/EU), providing updated exemption clauses for the use of lead in high melting point solder, metal alloys, and electronic and electrical components such as glass or ceramics, while clarifying the exemption period.

On September 8, 2025, the European Commission officially adopted three revised drafts regarding lead exemptions under the RoHS Directive (2011/65/EU). The revision involves the exemption clauses for high-frequency use in Annex III of the EU RoHS Directive, such as clauses 6 (a), 6 (a) - I, 6 (b), 6 (b) - I, 6 (b) - II, 6 (c), 7 (a), 7 (c) - I, and 7 (c) - II for steel alloys, aluminum alloys, copper alloys, high-temperature molten solder, and lead in electrical and electronic component glass or ceramics. These revisions provide updated exemption clauses for the use of lead in high melting point solder, metal alloys, and electrical and electronic component glass or ceramics, while clarifying the exemption period. At present, the official bulletin has not been officially released.

Specific terms

Regarding steel alloys, aluminum alloys, and copper alloys, the exemption of lead as an alloying element in steel, aluminum, and copper has been revised in the RoHS Directive (2011/65/EU) by the European Parliament and the Council. The 6 (a), 6 (a) - I, 6 (b), 6 (b) - I, 6 (b) - II, and 6 (c) in RoHS Appendix III have been replaced by new clauses that extend exemptions but add restrictive conditions.

Terms	Exemption content	Scope of application and validity period
6(a)	Lead, as an alloying element, has a maximum lead content of 0.35% (weight ratio) in steel and galvanized steel used for processing purposes	Valid until [12 months after the authorization instruction takes effect]
6(a)-Ⅰ	Lead, as an alloying element, has a maximum lead content of 0.35% (weight ratio) in steel used for processing purposes*	All categories are valid until June 30, 2027
6(a)-Ⅱ	Lead, as an alloying element, is used in batch hot-dip galvanized steel components with a maximum lead content of 0.2% by weight*	All categories are valid until June 30, 2027
6(b)	Lead, as an alloying element, is used in aluminum with a maximum lead content of 0.4% by weight	Valid until [18 months after the authorization instruction takes effect]
6(b)‑Ⅰ	Lead, as an alloying element, has a maximum lead content of 0.4% by weight, provided that the lead comes from recycled lead containing aluminum waste*	For categories 1-7 and 10, the validity period is 12 months after the authorization directive takes effect. For category 9 industrial monitoring and control instruments and category 11, the validity period is until June 30, 2027
6(b)‑Ⅱ	Lead, as an alloying element, has a maximum lead content of 0.4% (by weight) in aluminum used for processing purposes*	For categories 1-7 and 10, the validity period is 18 months after the authorization directive takes effect. For category 9 industrial monitoring and control instruments and category 11, the validity period is until June 30, 2027
6(b)‑Ⅲ	Lead, as an alloying element, is used in aluminum casting alloys with a maximum lead content of 0.3% (by weight), provided that the alloying element comes from recycled lead containing aluminum waste*	Classes 1-8, 9 (excluding industrial monitoring and control instruments), and 10, valid until June 30, 2027
6(c)	Copper alloys with a maximum lead content of 4% by weight*	Valid until June 30, 2027

*Exemption does not apply to electronic and electrical equipment (EEE) supplied to the public if the equipment or its touchable parts are likely to be ingested by children under normal or foreseeable conditions of use. However, if the following situations can be proven simultaneously, exemption shall apply:

-The lead release rate of such EEE or its touchable parts (whether coated or not) shall not exceed 0.05 μ g/cm2 per hour (equivalent to 0.05 μ g/h)

-For coated items, the coating is sufficient to ensure that EEE does not exceed this release rate for at least two years under normal or reasonably foreseeable conditions of use.

For the purpose of this footnote, if the individual size of the EEE or its accessible part is less than 5 centimeters, or the size of its detachable or protruding part is less than 5 centimeters, it is considered that the device or its accessible part can be placed in the mouth of a child.

Regarding high melting point solder, revise the Directive of the European Parliament and the Council on the exemption of lead in high melting point solder in the RoHS Directive (2011/65/EU). 7 (a) of Appendix III of the RoHS Directive has been replaced and updated, extending the exemption period until December 31, 2026, and 7 (a) - I~7 (a) - VII exemptions until December 31, 2027.

Terms	Exemption content	Scope of application and validity period
7(a)	Lead in high melting point solder (i.e. lead based alloys with lead content greater than or equal to 85%)	Applicable to all categories (excluding applications covered by point 24 of Annex III), valid until June 30, 2027
7(a)-Ⅰ	Lead in high melting point solder (i.e. lead based alloys with lead content greater than or equal to 85%), used for connecting internal interconnects of chips and other components in chips or semiconductor components, with steady-state or transient/pulse currents of 0.1 A or greater or blocking voltages exceeding 10V, or chip edge dimensions greater than 0.3mmx0.3 mm	Applicable to all categories (except for the applications mentioned in point 24 of Annex III), valid until December 31, 2027
7(a)-Ⅱ	Lead in high melting point solder (i.e. lead based alloys with a lead content of 85% or more), used for overall (i.e. internal and external) connection of chips in electronics and electrical systems, if all of the following conditions are met: - Thermal conductivity of cured/sintered chip bonding material>35W/(m * K) - Conductivity of cured/sintered chip bonding material>4.7MS/m - Solid phase line melting temperature higher than 260 ° C	Applicable to all categories (except for the applications mentioned in point 24 of Annex III), valid until December 31, 2027
7(a)-Ⅲ	Lead in high melting point solder (i.e. lead based alloys with a lead content of 85% or more) used in primary solder joints (internal or integral connections - referring to internal and external) for manufacturing electronic components, in order to prevent reflow of primary solder when subsequently using secondary solder to mount electronic components onto sub components (i.e. modules, sub circuit boards, substrates, or point-to-point soldering). This entry does not include chip connection applications and airtight sealing	Applicable to all categories (except for the applications mentioned in point 24 of Annex III), valid until December 31, 2027
7(a)-Ⅳ	Lead in high melting point solder (i.e. lead based alloys with a lead content greater than or equal to 85%) used to connect components to secondary solder joints of printed circuit boards or lead frames: 1. Solder balls used to connect ceramic ball grid arrays (BGA) 2. High temperature plastic encapsulation molds (>220 ° C)	Applicable to all categories (except for the applications mentioned in point 24 of Annex III), valid until December 31, 2027
7(a)-Ⅴ	Lead in high melting point solder (i.e. lead based alloys with a lead content greater than or equal to 85%) is used as a sealing material between the following components: 1 Ceramic packaging or plug with metal casing 2 Component terminals and internal sub components	Applicable to all categories (except for the applications mentioned in point 24 of Annex III), valid until December 31, 2027
7(a)-Ⅵ	Lead in high melting point solder (i.e. lead based alloys with a lead content of 85% or more by weight) is used to establish electrical connections between lamp tube components in infrared heated incandescent reflector lamps, high-intensity gas discharge lamps, or oven lamps	Applicable to all categories (except for the applications mentioned in point 24 of Annex III), valid until December 31, 2027
7(a)-Ⅶ	Lead in high melting point solder (i.e. lead based alloys with a lead content of 85% or more by weight) used for audio transducers with peak operating temperatures exceeding 200 ° C	Applicable to all categories (except for the applications mentioned in point 24 of Annex III), valid until December 31, 2027

Regarding electrical and electronic components such as glass and ceramics, revise the Directive of the European Parliament and the Council on the exemption of lead in glass or ceramic components under the RoHS Directive (2011/65/EU). The 7 (c) - I and 7 (c) - II in Appendix III of the RoHS Directive have been replaced by new provisions extending the exemption period until December 31, 2026 and December 31, 2027, and adding 7 (c) - V and 7 (c) - V.

(1) Replace exemption clauses 7 (c) - I and 7 (c) - II with the following:

Terms	Exemption content	Scope of application and validity period
7(c)-Ⅰ	Electrical and electronic components containing lead in glass or ceramics (excluding dielectric ceramics in capacitors), such as piezoelectric devices, or electrical and electronic components containing lead in glass or ceramic matrix compounds	Applicable to all categories, valid until June 30, 2027
7(c)-Ⅱ	Lead in dielectric ceramics for capacitors with a rated voltage of 125 V AC or 250 V DC or higher	Applicable to all categories (except for applications at points 7 (c) - I or 7 (c) - IV), valid until December 31, 2027

（2）Add clauses 7 (c) - V and 7 (c) - VI:

Terms	Exemption content	Scope of application and validity period
7(c)-Ⅴ	Electrical and electronic components containing lead in glass or glass matrix compounds, with any of the following functions: 1) used for protection and electrical insulation of high-voltage diode glass beads and chip glass layers; 2) used for sealing between ceramic, metal, and/or glass components; 3) used for bonding at a process parameter window of<500 ° C and a viscosity of 1013.3 dPas ("glass transition temperature"); 4) used as resistance materials such as ink, with a resistivity range of 1 ohm/square to 100 megaohms/square, excluding fine adjustment potentiometers; 5) used for chemically modified glass surfaces of microchannel plates (MCP), channel electron multipliers (CEM), and resistance glass products (RGP)	Applicable to all categories, valid until December 31, 2027
7(c)-Ⅵ	Electrical and electronic components containing lead in ceramics that meet any of the following functions: 1) Used for piezoelectric lead zirconate titanate (PZT) ceramics; 2) Providing ceramics with a positive temperature coefficient (PTC)	Applicable to all categories (except for applications covered by points 7 (c) - II, 7 (c) - III, and 7 (c) - IV of Annex III and point 14 of Annex IV), valid until December 31, 2027

Core content

The three revisions adopted this time mainly focus on the exemption clauses in Annex III of the RoHS Directive, as follows:

Exemption for lead in high melting point solder: Article 7 (a) stipulates that lead based alloy solder with a lead content of 85% or more can be used for specific high-temperature applications, but this exemption is valid until December 31, 2026.

The exemption period for certain categories of high melting point solder has been extended until December 31, 2027, subject to strict conditions.

Exemption for lead in steel, aluminum, and copper alloys: Article 6 (a) allows lead to be used as an alloying element for processing purposes in steel and galvanized steel, with a maximum lead content of 0.35% by weight. This exemption is valid for 12 months after the authorization directive takes effect.

The exemption period for other related clauses (such as 6 (b), 6 (c), etc.) mostly expires on December 31, 2026.

Exemption for lead in glass or ceramics for electronic and electrical components: Article 7 (c) - I applies to electrical and electronic components (such as piezoelectric devices) containing lead in glass or ceramics (excluding dielectric ceramics in capacitors), valid until December 31, 2026.

Article 7 (c) - II exempts lead in dielectric ceramics in capacitors with a rated voltage of 125 V AC or 250 V DC or higher until December 31, 2027.

Newly added clauses 7 (c) - V and 7 (c) - VI provide more detailed exemption provisions for the use of lead in specific types of dielectric ceramics and glass ceramic materials.

Main influences

The update of RoHS exemption clauses has a significant impact on the electronic and electrical related industries, especially the extension of some exemption clauses that are frequently used by enterprises, which may directly affect the production process and business activities of enterprises.

Compliance pressure increases: The European Union is gradually tightening the use of lead, and Chinese export companies that rely on lead containing materials (solder, alloys, piezoelectric ceramics, etc.) must layout alternative technologies in advance.

Supply chain requirements increase: The EU has set an exemption expiration date (2026-2027), and importers may require suppliers to provide lead-free or low lead versions before this date to reduce future compliance risks. Chinese component manufacturers need to re evaluate the BOM (Bill of Materials) and confirm alternative materials with upstream suppliers.

Product design and certification impact: Once the exemption expires, lead containing components will directly affect CE marking and market access. Especially for products that are accessible to children (consumer electronics, small appliances, toy electronics), the requirements are more stringent.

Cost and technical challenges: Alternative solder materials (such as lead-free high-temperature solder) typically have higher costs and longer reliability verification cycles. Export enterprises need to conduct reliability testing and lifecycle assessment of substitute products in advance to avoid future passivity.

Compliance Service

The EU RoHS remains a key enforcement focus, with a large number of electronic and electrical products being punished to varying degrees every year for violating the RoHS directive. The revision of the EU RoHS directive will have a significant impact on the electronics and electrical industry. It is recommended that relevant companies pay close attention to and continuously track the revision dynamics of the EU RoHS directive, keep up with the development pace of the RoHS directive, conduct timely supply chain investigation and control, so as to quickly comply with regulatory requirements and seize market opportunities when the regulations are updated.

Jiayu Testing has rich project experience in the field of RoHS hazardous substance control. Relying on advanced instruments and professional laboratory technology teams, we provide customized raw material and whole machine restricted substance testing solutions for customers, assist enterprises in actively responding to regulatory requirements, help enterprises achieve hazardous substance risk control, and effectively improve product compliance. Welcome to contact us at 400-9269-886 !