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EU Updates RoHS lead-related Exemptions

On November 21, 2025, the European Commission published new directives—(EU) 2025/2364, (EU) 2025/1802, and (EU) 2025/2363—in the Official Journal (OJ), amending Annex III of the RoHS Directive. These revisions adjust several frequently used exemption clauses concerning lead content in steel alloys, aluminum alloys, copper alloys, high-temperature solder, and glass/ceramics in electrical and electronic components. The updated regulations will take effect on December 11, 2025.


1. (EU) 2025/2364: Lead in Steel, Aluminum, and Copper Alloys

Exemptions 6(a), 6(a)-I, 6(b), 6(b)-I, 6(b)-II, and 6(c) have been replaced with the following:


Clause

No.

Exemption Regulations

Date and Scope of Application

6(a)

Lead is used as an alloying element, and the lead content in machined steel and galvanized steel is ≤0.35% (w/w).

Expires on December 11, 2026

6(a)-I

Lead is used as an alloying element, and the lead content in steel used for machining is ≤0.35% (w/w).

Applicable to all categories,

expiring June 30, 2027.

6(a)-II

Lead, as an alloying element, is used in batches of hot-dip galvanized steel with a lead content ≤0.2% (w/w).

Applicable to all categories,

expiring June 30, 2027.

6(b)

Lead is used as an alloying element in aluminum with a lead content ≤ 0.4% (w/w).

Expires on June 11, 2026

6(b)-I

In the recycled lead-containingscrap aluminum, the lead content as an alloying element is ≤0.4% (w/w).

Applicable to Classes 1-7; Class 10: expires December 11, 2026;

Applicable to Class 9 industrial monitoring equipment and Class 11:

expires June 30, 2027.

6(b)-II

For aluminum used in machining, the lead content as an alloying element is ≤ 0.4% (w/w).

Applicable to Classes 1-7; Class 10: expires June 11, 2027;

Applicable to Class 9 industrial monitoring equipment and Class 11:

expires June 30, 2027.

6(b)-III

In the recycled lead-containing scrap aluminum, the lead content of the aluminum casting alloy is ≤0.3% (w/w).

Applicable to Classes 1-8, and Classes 9 and 10

excluding industrial monitoring equipment,

expiring on June 30, 2027.

6(c)

The lead content in copper alloys is ≤ 4% (w/w).

Expires on June 30, 2027


The exemption does not apply to electrical and electronic equipment (EEE) supplied to the general public if the equipment or its accessible parts may be placed in children’s mouths during normal or reasonably foreseeable use. However, the exemption may apply if the following conditions are met:



Note: EEE or its accessible parts are considered mouthable if any single dimension is less than 5 cm, or if detachable/protruding parts are smaller than 5 cm.


2. (EU) 2025/1802: High-Temperature Solder

Exemption 7(a) has been revised to include updated requirements for lead-containing high-temperature solders.

Clause

No.

Exemption Regulations

Date and Scope of Application

7(a)

Lead in high-melting-point solder

(i.e., lead-based alloy solder, with a lead content exceeding 85%)

Applicable to all categories except those covered in point 24 of Annex III, expiring on June 30, 2027.

7(a)-I

Lead in high-melting-point solders  (i.e., lead-based alloy solders with a lead content

exceeding 85%) is used for internal interconnects to connect chips or other components to chips within semiconductor assemblies in semiconductor assemblies with steady-state or transient/pulse currents of 0.1A or greater, blocking voltages exceeding 10V, or chip edge dimensions greater than 0.3mm x 0.3mm.

Applicable to all categories except those covered in point 24 of Annex III, expiring on December 31, 2027.

7(a)-II

For high-melting-point solders (i.e., lead-based alloy solders with a lead content exceeding 85%), the following conditions must be met for overall (internal and external) chip-to-chip connections in electrical and electronic components:

- Thermal conductivity of the cured/sintered chip-to-chip bonding material greater than 35 W/(m×K);

- Electrical conductivity of the cured/sintered chip-to-chip bonding material greater than 4.7 MS/m;

- Solidus melting temperature higher than 260℃

Applicable to all categories except those covered in point 24 of Annex III, expiring on December 31, 2027.

7(a)-III

The lead in the high-melting-point solder (i. e., lead-based alloy solder with a lead content exceeding 85%) used in the first-level solder joints (internal or integral connections – referring to both internal and external connections) ensures that the first-level solder does not flow back when the electronic component is subsequently mounted onto a sub-assembly (i. e., module, sub-circuit board, substrate, or point-to-point soldering) using the second-level solder. This entry does not include chip-to-chip bonding applications and sealing.

Applicable to all categories except those covered in point 24 of Annex III, expiring on December 31, 2027.

7(a)-IV

Lead in high-melting-point solders (i.e., lead-based alloy solders with a lead content exceeding 85%) is used in secondary solder joints for

connecting components to printed circuit boards or lead frames:

1) In solder balls used to connect ceramic ball grid arrays (BGA)

2) In high-temperature plastic over molding (> 220°C)

Applicable to all categories except those covered in point 24 of Annex III, expiring on December 31, 2027.

7(a)-V

Lead in high-melting-point solders (i.e., lead-based alloy solders with a lead content exceeding 85%) is used as a sealing material in:

1) ceramic packages or plugs and metal housings;

2) component terminals and internal sub-components.

Applicable to all categories except those covered in point 24 of Annex III, expiring on December 31, 2027.

7(a)-VI

Lead in high-melting-point solder (i.e., lead-based alloy solder with a lead content exceeding 85%) is used to establish electrical connections between lamp components in incandescent reflector lamps for infrared heating, high-intensity discharge lamps, or oven lamps.

Applicable to all categories except those covered in point 24 of Annex III, expiring on December 31, 2027.

7(a)-VII

Lead in high-melting-point solders (i.e., lead-based alloy solders with a lead content exceeding 85%) is used in audio sensors with peak operating temperatures exceeding 200°C.

Applicable to all categories except those covered in point 24 of Annex III, expiring on December 31, 2027.


3.  (EU) 2025/2363: Lead in Glass/Ceramics for EEE

1)Exemptions 7(c)-I and 7(c)-II have been replaced with updated clauses.


Clause

No.

Exemption Regulations

Date and Scope of Application

7(c)-I

Electrical and electronic components (such as piezoelectric devices) containing

lead in glass or ceramic (excluding dielectric ceramics in capacitors), or electrical and

electronic components containing lead in glass or ceramic matrix compounds.

Applicable to all categories,

expiring June 30, 2027.

7(c)-II

Lead in the dielectric ceramic of capacitors with rated voltage of 125V AC or 250V DC and above

Applicable to all categories

except those covered by Section 7(c)-I or 7(c)-IV, expiring on December 31, 2027.


2) 7(c)-V and 7(c)-VI, have been added to address specific applications of lead in glass and ceramic components.


Clause No.

Exemption Regulations

Date and Scope of Application

7(c)-V

Electrical and electronic components containing lead in glass or glass matrix compounds, having any of the following functions:

1) Protection and electrical insulation for high-voltage diode glass beads and wafer glass layers

2) Sealing between ceramic, metal, and/or glass components

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

4) Used as resistive materials such as inks, with resistivity ranging from 1 ohm/square to 100 megohms/square, excluding trimmer potentiometers

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

Applicable to all categories,

expiring December 31, 2027.

7(c)-VI

Lead-containing electrical and electronic components in ceramics that have any of the following functions:

1) Piezoelectric lead zirconium titanate (PZT) ceramics

2) Ceramics providing a positive temperature coefficient (PTC)

Applicable to all categories except those covered by Annex III, Clauses 7(c)-II, 7(c)-III, 7(c)-IV and Clause 14 of Annex IV, expiring on December 31, 2027.


HUAK Testing reminds relevant enterprises to:

With extensive experience in RoHS compliance, HUAK Testing offers comprehensive testing solutions, technical consultations, and tailored support to help businesses navigate these changes seamlessly.


HUAK Testing Certification Service Advantages

HUAK Testing covers an area of over 4,000 square meters, including EMC, RF, 5G NR/6G (RF), Safety, Physical, Battery, and Chemical testing laboratories. It supports a wide range of products—from consumer goods like mobile phones, computers, toys, apparel, footwear, and cosmetics, to industrial control equipment and smart home devices—helping clients meet global market access requirements. The company is equipped with internationally advanced professional testing equipment and has assembled an elite team of senior industry experts and technical professionals. Team members, with their solid professional knowledge and rich practical experience, are able to accurately interpret various complex standards and technical requirements. As a well-known third-party testing laboratory in China, HUAK has been recognized by many international organizations, including the China National Accreditation Service(CNAS) for Conformity Assessment and the US A2LA. HUAK Testing is also the designated testing and certification service provider for Amazon, and maintains close cooperation with internationally renowned notified bodies such as MICOM, element, MET, and Germany's PHOENIXTESTLAB GmbH.




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