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EU RoHS revises multiple lead exemption clauses, which have these impacts on electronic and electrical companies!

Time：

2025-11-25

The European Commission has officially issued directives (EU) 2025/2363, (EU) 2025/2364, and (EU) 2025/1802, updating the lead exemption clauses in Annex III of the EU RoHS Directive regarding steel alloys, aluminum alloys, copper alloys, high melting point solder materials, and glass and ceramic electrical and electronic components.

On November 21, 2025, the European Commission officially issued directives (EU) 2025/2363, (EU) 2025/2364, and (EU) 2025/1802, updating the lead exemption clauses in Annex III of the EU RoHS Directive regarding steel alloys, aluminum alloys, copper alloys, high melting point solder, and electrical and electronic components such as glass and ceramics. This directive will come into effect on the 20th day after its publication (December 11, 2025).

In addition to updating or adding exemption clauses, the exemption for lead in alloys has also been added, which means that electronic and electrical equipment supplied to the public, or their touchable parts that may be put into the mouth of children under normal or foreseeable conditions of use, cannot be exempted unless specific conditions can be proven to be met. Jiayu Testing provides one-stop RoHS testing and certification services to safeguard your products. Welcome to inquire!

Specific terms

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 The 6 (a), 6 (a) - I, 6 (b), 6 (b) - I, 6 (b) - II, and 6 (c) in RoHS Appendix III have been replaced by new clauses that extend exemptions but add restrictive conditions.

Clause Content	Scope of application and validity period
6 (a) Lead as an alloying element in steel for mechanical processing, and lead content in galvanized steel not exceeding 0.35% by weight.	Validity period: until December 11, 2026
6 (a) - I. Lead as an alloying element in steel for mechanical processing, with a content not exceeding 0.35% by weight. *	Scope of application: All categories; Validity period: until June 30, 2027
6 (a) - II. The lead content as an alloying element in batch heat treated galvanized steel components shall not exceed 0.2% by weight. *	Scope of application: All categories; Validity period: until June 30, 2027
6 (b) Lead as an alloying element in aluminum, with a content not exceeding 0.4% by weight.	Validity period: until June 11, 2027
6 (b) - I. Lead as an alloying element in aluminum, with a content not exceeding 0.4% (by weight), comes from lead containing aluminum waste. *	Scope of application: Classes 1-7, 9 (industrial monitoring and control instruments), 10, 11; Validity period: a. Until December 11, 2026 (for categories 1-7 and 10); b. June 30, 2027 (for Class 9 (Industrial Monitoring and Control Instruments) and Class 11).
6 (b) - II. For mechanical processing purposes, lead is an alloy with a content not exceeding 0.4% by weight in aluminum alloys. *	Scope of application: Classes 1-7, 9 (industrial monitoring and control instruments), 10, 11; Validity period: a. Until June 11, 2027 (for categories 1-7 and 10); b. June 30, 2027 (for Class 9 (Industrial Monitoring and Control Instruments) and Class 11)
6 (b) - III. Lead as an alloying element in aluminum casting alloys, with a content not exceeding 0.3% by weight, comes from lead containing aluminum waste. *	Scope of application: Classes 1-8, 9 (excluding industrial monitoring and control instruments), and 10; Validity period: until June 30, 2027
6 (c) Lead in copper alloys, with a content not exceeding 4% by weight*	Validity period: 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 the exemption of lead in 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.

Clause Content	Scope of application and validity period
7 (a) Lead in high melting point solder (i.e. lead based alloy solder with lead content exceeding 85%).	Scope of application: All categories (excluding applications covered by Article 24 of this Annex); Validity period: until June 30, 2027
7 (a) - I. Lead in newly added melting point solder (i.e. lead based alloys with a lead content of 85% or more), used for internal interconnection in semiconductor packaging to attach chips or other components, as well as components used with chips, suitable for steady-state or transient/pulse currents of 0.1A or greater, or blocking voltages exceeding 10V, or chip edge sizes greater than 0.3mm x 0.3mm.	Scope of application: All categories (excluding applications covered by Article 24 of this Annex); Validity period: 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 the overall (i.e. internal and external) connection of chip bonding in electrical and electronic components, if all of the following conditions are met: - the thermal conductivity of the cured/sintered chip bonding material>35W/(m * K), - the electrical conductivity of the cured/sintered chip bonding material>4.7ms/m, - the solidus melting temperature is higher than 260 ° C.	Scope of application: All categories (excluding applications covered by Article 24 of this Annex); Validity period: 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.	Scope of application: All categories (excluding applications covered by Article 24 of this Annex); Validity period: 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: - Lead in solder balls used to connect ceramic ball grid arrays (BGA); -High temperature plastic encapsulation mold (>220 ° C)	Scope of application: All categories (excluding applications covered by Article 24 of this Annex); Validity period: until December 31, 2027
7 (a) - V. Lead in high melting point solder (i.e. lead based alloys with a lead content of 85% or more), used as a sealing material between ceramic packaging or plugs and metal casings, and between component terminals and internal sub components.	Scope of application: All categories (excluding applications covered by Article 24 of this Annex); Validity period: 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), used to establish electrical connections between lamp components in infrared heated incandescent reflector lamps, high-intensity discharge lamps, or oven lamps.	Scope of application: All categories (excluding applications covered by Article 24 of this Annex); Validity period: 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), used for audio sensors with peak operating temperatures exceeding 200 ° C.	Scope of application: All categories (excluding applications covered by Article 24 of this Annex); Validity period: until December 31, 2027

Revise the Directive of the European Parliament and the Council on the Exemption of Lead in Glass or Ceramic Components for Electrical and Electronic 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.

Clause Content	Scope of application and validity period
7 (c) - I. Lead contained in glass or ceramic materials (excluding ceramic dielectrics in capacitors) in electronic and electrical components, such as piezoelectric devices or glass/ceramic composite components.	Scope of application: All categories; Validity period: June 30, 2027
7 (c) - I. Lead contained in ceramic dielectrics in capacitors with rated voltage of AC 125 V or DC 250 V or above, except for the applications in Articles 7 (c) - I and 7 (c) - IV;	Scope of application: All categories; Validity period: December 31, 2027
7 (c) - V. Electrical and electronic components containing lead in glass or glass matrix compounds that can achieve any of the following functions: 1) Used for protection and electrical insulation in high-voltage diode glass beads and wafer glass layers; 2) Used for sealing between ceramic, metal, and/or glass components; 3) For bonding purposes within the process parameter window of<500 ° C, with a viscosity of 1013.3 dPas ("glass transition temperature"); 4) Used as a resistive material (such as ink) with a resistivity range of 1 ohm/square to 100 megaohms/square, excluding fine adjustment potentiometers; 5) Chemical modified glass surfaces for microchannel plates (MCP), channel electron multipliers (CEM), and resistance glass products (RGP).	Scope of application: All categories; Validity period: December 31, 2027
7 (c) - VI contains lead in ceramics that meet any of the following functions in electrical and electronic components (excluding items covered in Articles 7 (c) - II, 7 (c) - III, and 7 (c) - IV of this Annex and Article 14 of Annex IV): 1) used for piezoelectric lead zirconate titanate (PZT) ceramics; 2) Used to provide ceramics with a positive temperature coefficient (PTC).	Scope of application: All categories; Validity period: December 31, 2027

Main Effect

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.

As a professional third-party testing and certification service organization, Jiayu Testing has qualifications such as CMA, CNAS, CPSC, and has obtained laboratory accreditation from multiple authoritative certification agencies at home and abroad. The laboratory is strictly built and managed according to standards, equipped with advanced instruments and equipment, and has a skilled professional technical team with rich industry service experience and strong testing technology capabilities. It is proficient in various regulatory standards. Jiayu Testing has rich project experience in the field of RoHS hazardous substance control, providing customized raw material and complete machine restricted substance testing solutions for customers, assisting enterprises in actively responding to regulatory requirements, helping enterprises achieve hazardous substance risk control, and effectively improving product compliance. Welcome to contact us at 400-9269-886!