The EU Restriction of Hazardous Substances Directive (RoHS) is tightening certain exemptions for lead alloys. The relevant delegated directives were published in the EU Official Journal on 21 November 2025 and have been in force since 11 December 2025.
In this context, some key deadlines are approaching:
- 11 December 2026: Some existing exemptions expire.
- 30 June 2027: Some exemptions for alloy variants expire.
No further extensions are currently planned. Once the exemptions expire, standard RoHS lead limits will apply. Products that fail to meet these limits may no longer be placed on the EU market.
Which components are affected?
The changes focus on components covered by exemptions 7a, 7c-I and 6a/6c. For some applications, however, technically equivalent and qualified alternatives may not yet be available. This may result in components becoming obsolete or supply chain disruptions.
Therefore, producers and importers should review the following:
- Product configurations and affected components
- Suppliers and supply chain risks
- Technical documentation
- Change management processes and potential alternatives
Depending on the product life cycle, a last-time-buy strategy may also be worth considering. But early coordination and assessment can help prevent supply shortages and ensure that future product variants meet RoHS requirements on time.
Need help with RoHS compliance? Contact the trade-e-bility team for a solution that is tailored to your needs.
