RoHS Directive Amendments: Lead Exemptions Detailed
Commission Delegated Directive (EU) 2025/1802
This directive amends the RoHS Directive (2011/65/EU) by refining an exemption concerning lead in high melting temperature solders. Instead of a broad exemption, it introduces seven specific sub-entries (7(a)-I to 7(a)-VII) within Annex III. Each sub-entry now delineates precise applications and conditions under which lead can still be used in these solders. These applications range from internal interconnections and die attach to hermetic sealing and usage in specific lamps and audio transducers. The original exemption 7(a) applies to all categories (except applications covered by point 24 of this Annex) and expires on 30 June 2027. The sub-entries 7(a)-I to 7(a)-VII apply to all categories (except applications covered by point 24 of this Annex) and expire on 31 December 2027.
Commission Delegated Directive (EU) 2025/2363
This directive also modifies the RoHS Directive (2011/65/EU), focusing on exemptions for lead in glass or ceramic components. Annex III is amended by replacing points 7(c)-I and 7(c)-II and introducing new points 7(c)-V and 7(c)-VI. The original exemptions are now segmented into categories based on lead applications in glass versus ceramic. Each category receives a distinct expiry date. Key provisions include:
- 7(c)-I: Addresses lead in glass or ceramic components (excluding dielectric ceramic in capacitors) and expires on 30 June 2027.
- 7(c)-II: Covers lead in dielectric ceramic in capacitors for a rated voltage of 125 V AC or 250 V DC or higher and expires on 31 December 2027.
- 7(c)-V: Specifies lead functions in glass or glass matrix compounds, such as protection, electrical insulation, hermetic sealing, and bonding, and expires on 31 December 2027.
- 7(c)-VI: Specifies lead functions in ceramic, such as use in piezoelectric lead zirconium titanate (PZT) ceramics and for providing ceramics with a positive temperature coefficient (PTC) and expires on 31 December 2027.
Member States are required to implement these changes into national law by 30 June 2026, with application starting from 1 July 2026.
Review of each of legal acts published today:
Commission Delegated Directive (EU) 2025/1802 of 8 September 2025 amending Directive 2011/65/EU of the European Parliament and of the Council as regards an exemption for lead in high melting temperature solders
This Commission Delegated Directive (EU) 2025/1802 amends Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS Directive) by modifying an exemption related to lead in high melting temperature solders. The amendment involves replacing the existing exemption with several sub-entries that specify particular applications and conditions under which the exemption for lead in these solders continues to apply.
The Directive modifies Annex III of Directive 2011/65/EU, specifically addressing point 7(a) concerning lead in high melting temperature type solders. Instead of a single exemption, it introduces seven sub-entries (7(a)-I to 7(a)-VII), each detailing specific applications and technical conditions for the continued use of lead. These applications include internal interconnections in electrical and electronic equipment, integral connections of die attach, first-level solder joints, second-level solder joints, hermetic sealing materials, solders in certain lamps, and audio transducers. The original exemption 7(a) applies to all categories (except applications covered by point 24 of this Annex) and expires on 30 June 2027. The sub-entries 7(a)-I to 7(a)-VII apply to all categories (except applications covered by point 24 of this Annex) and expire on 31 December 2027.
The most important provision is the segmentation of the original exemption into seven specific sub-entries, each with defined conditions and application areas. This change requires manufacturers to carefully assess their use of high melting temperature solders containing lead to determine which, if any, of the new sub-entries apply to their products. The Directive also sets specific expiration dates for the original exemption and the new sub-entries, providing a timeline for compliance and potential need for further renewal requests.
Commission Delegated Directive (EU) 2025/2363 of 8 September 2025 amending Directive 2011/65/EU of the European Parliament and of the Council as regards an exemption for lead in glass or ceramic components
This Commission Delegated Directive (EU) 2025/2363 amends Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS Directive). The amendment concerns an exemption for lead in glass or ceramic components, specifically addressing the applications and validity periods for these exemptions. The directive aims to adapt the existing regulations to scientific and technical progress, ensuring that exemptions are granted only when technically or scientifically necessary and that the environmental and health protection is maintained.
The directive modifies Annex III of Directive 2011/65/EU. It replaces the existing points 7(c)-I and 7(c)-II and adds new points 7(c)-V and 7(c)-VI. The original exemptions for lead in glass or ceramic components are split into more specific categories based on their applications. Specifically, it distinguishes between lead in glass applications and lead in ceramic applications. Each category is assigned a specific expiry date. The new structure allows for a more focused technical assessment of each application in the future.
The most important provisions of this directive are the redefined categories and the new expiry dates for the exemptions.
– **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. This exemption applies to all categories and expires on 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. This applies to all categories (except applications covered by point 7(c)-I or 7(c)-IV) and expires on 31 December 2027.
– **7(c)-V**: Details specific functions for lead in glass or glass matrix compounds, such as protection and electrical insulation, hermetic sealing, bonding, resistive material, and use in chemically modified glass surfaces. This exemption applies to all categories and expires on 31 December 2027.
– **7(c)-VI**: Details specific functions for lead in ceramic, such as use in piezoelectric lead zirconium titanate (PZT) ceramics and for providing ceramics with a positive temperature coefficient (PTC). This applies to all categories (except applications covered by points 7(c)-II, 7(c)-III and 7(c)-IV of this Annex as well as point 14 of Annex IV) and expires on 31 December 2027.
Member States must adopt and publish the laws, regulations, and administrative provisions necessary to comply with this Directive by 30 June 2026, and they shall apply those provisions from 1 July 2026.
