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EU: Comprehensive updates to lead exemptions under RoHS directive

November 2025 - Electrical and electronics

On 21 November 2025, the European Commission (EC) adopted three (3) Delegated Directives (EU) 2025/18021, 2025/23632, and 2025/23643, amending Annex III to Directive 2011/65/EU (Restriction of the use of certain hazardous substances in electrical and electronic equipment (EEE), or RoHS). These updates focus on renewing and segmenting specific exemptions for the use of lead in certain applications, a restricted substance generally limited to a maximum tolerated concentration value of 0.1% by weight in homogenous materials in EEE placed on the market.

The amendments are the result of detailed technical and scientific assessment studies conducted between 2022 and 2024, alongside multiple rounds of stakeholder consultations. This process ensures that exemptions are granted only where elimination or substitution is scientifically or technically impracticable, or where the reliability of substitutes cannot be ensured.

Table A: Directive (EU) 2025/1802 as regards exemptions for lead in high melting temperature solders (i.e., lead-based alloys containing 85% by weight or more lead)

Entry
Description
Applicability
Expiry Date

7(a)

Lead in high melting temperature type solders

Applies to all categories (except applications covered by entry 24 of Annex III)

30 June 2027

7(a)-I

Lead in high melting temperature type solders for internal interconnections for attaching die, or other components along with a die in semiconductor assembly with steady state or transient/impulse currents of 0,1 A or greater or blocking voltages beyond 10 V, or die edge sizes larger than 0.3 mm × 0.3 mm

Applies to all categories (except applications covered by entry 24 of Annex III)

31 December 2027

7(a)-II

Lead in high melting temperature type solders for integral connections of die attach in electrical/electronic components if:

- thermal conductivity of cured/sintered die-attach material ≥35 W/m·K,

- electrical conductivity ≥4.7 MS/m,

- solidus melting temperature >260 °C

Applies to all categories (except applications covered by entry 24 of Annex III)

31 December 2027

7(a)-III

Lead in high melting temperature type solders in first level solder joints (internal or integral connections – meaning internal and external) for manufacturing components so that subsequent mounting of electronic components onto subassemblies (i.e. modules, sub-circuit boards, substrates, or point-to-point soldering) with a secondary solder does not reflow the first level solder. This sub-entry excludes die attach applications and hermetic sealings

Applies to all categories (except applications covered by entry 24 of Annex III)

31 December 2027

7(a)-IV

Lead in high melting temperature type solders in second level solder joints for the attachment of components to printed circuit board or lead frames:

(1) in solder balls for the attachment of ceramic ball-grid-array (BGA);

(2) in high temperature plastic overmouldings > 220 °C

Applies to all categories (except applications covered by entry 24 of Annex III)

31 December 2027

7(a)-V

Lead in high melting temperature type as a hermetic sealing material between:

a ceramic package or plug and a metal case;

component terminations and an internal sub-part

Applies to all categories (except applications covered by entry 24 of Annex III)

31 December 2027

7(a)-VI

Lead in high melting temperature type solders for establishing electrical connections between lamp components in incandescent reflector lamps for infrared heating, high intensity discharge lamps, or oven lamps

Applies to all categories (except applications covered by entry 24 of Annex III)

31 December 2027

7(a)-VII

Lead in high melting temperature type solders for audio transducers where the peak operating temperature exceeds 200 °C

Applies to all categories (except applications covered by entry 24 of Annex III)

31 December 2027

Table B: Directive (EU) 2025/2363 as regards exemptions for lead in glass or ceramic components

Entry
Description
Applicability
Expiry Date

7(c)-I

Electrical and electronic components containing lead in a glass or ceramic other than dielectric ceramic in capacitors, e.g., piezoelectronic devices, or in a glass or ceramic matrix compound


Applies to all categories

30 June 2027

7(c)-II

Lead in dielectric ceramic in capacitors for a rated voltage of 125 V AC or 250 V DC or higher

Applies to all categories (except applications covered by entry7(c)-I or 7(c)-IV)

31 December 2027

7(c)-V (NEW)

Electrical and electronic components containing lead in a glass or glass matrix compound that fulfils any of the following functions:

(1) for protection and electrical insulation in glass beads of high-voltage diodes and glass layers for wafers;

(2) for hermetic sealing between ceramic, metal and/or glass parts;

(3) for bonding purposes in a process parameter window for < 500 °C combined with a viscosity of 1013.3 dPas (“glass-transition temperature”);

(4) for use as a resistive material such as ink, with a resistivity range from 1 ohm/square to 100 megohm/square, excluding trimmer potentiometers;

(5) for use in chemically modified glass surfaces for microchannel plates (MCPs), channel electron multipliers (CEMs) and resistive glass products (RGPs).

Applies to all categories

31 December 2027

7(c)-VI (NEW)

Electrical and electronic components containing lead in a ceramic that fulfils any of the following functions:

(1) for use in piezoelectric lead zirconium titanate (PZT) ceramics;

(2) for providing ceramics with a positive temperature coefficient (PTC).

Applies to all categories (except applications covered by entry 7(c)-II, 7(c)-III and 7(c)-IV of Annex III, as well as entry 14 of Annex IV)

31 December 2027

Table C: Directive (EU) 2025/2364 as regards exemptions for lead as an alloying element in steel, aluminium and copper

Entry
Description
Expiry Details

6(a)

Lead as an alloying element in steel for machining purposes and in galvanised steel containing up to 0.35% lead by weight

11 December 2026

6(a)-I

Lead as an alloying element in steel for machining purposes containing up to 0.35% lead by weight (*)

30 June 2027

6(a)-II

Lead as an alloying element in batch hot-dip galvanised steel components containing up to 0.2% lead by weight (*)

30 June 2027

6(b)

Lead as an alloying element in aluminium containing up to 0.4% lead by weight

11 June 2027

6(b)-I

Lead as an alloying element in aluminium containing up to 0.4% lead by weight, provided it stems from lead-bearing aluminium scrap recycling (*)

  • 11 December 2026 for categories 1-7, 10;
  • 30 June 2027 for categories 9 industrial monitoring and control instruments, and 11

6(b)-II

Lead as an alloying element in aluminium for machining purposes with a lead content up to 0.4% by weight (*)

  • 11 June 2027 for categories 1-7, 10;
  • 30 June 2027 for categories 9 industrial monitoring and control instruments, and 11

6(b)-III

Lead as an alloying element in aluminium casting alloys containing up to 0.3% lead by weight provided it stems from lead-bearing aluminium scrap recycling (*)

30 June 2027 for categories 1-8, 9 other than industrial monitoring and control instruments, and 10

6(c)

Copper alloy containing up to 4% lead by weight (*)

30 June 2027

(*) The exemption shall not cover EEE for supply to the general public where the EEE or accessible part thereof may, during normal or foreseeable conditions of use, be placed in the mouth by children. However, the exemption shall apply where the following can be both demonstrated:

— the rate of lead release from such an EEE or any accessible part, whether coated or uncoated, does not exceed 0,05 μg/cm2 per hour (equivalent to 0,05 μg/g/h),

— for coated articles, that the coating is sufficient to ensure that this release rate is not exceeded for a period of at least two years of normal or reasonably foreseeable conditions of use of the EEE.

For the purpose of this footnote, it is considered that an EEE or accessible part of an EEE may be placed in the mouth by children if it is smaller than 5 cm in one dimension or has a detachable or protruding part of that size.

 

References:

[1] Delegated Directives (EU) 2025/1802

[2] Delegated Directives (EU) 2025/2363

[3] Delegated Directives (EU) 2025/2364


 

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