🔎 Introduction

The European Union has officially updated several Annex III exemptions of the Restriction of Hazardous Substances (RoHS) Directive 2011/65/EU.
These updates—published on 8 September 2025—extend or phase out key exemptions for lead in steel, aluminium, copper, solders, glass, and ceramics.

This article summarizes the new delegated directives, clarifies which exemptions remain valid and which have expired, and explains how manufacturers can still apply for renewals before the 2027 sunset dates.

🧩 What Are Annex III & IV Exemptions?

Under RoHS, hazardous substances like lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP are restricted.
However, exemptions in:

• Annex III apply to all EEE categories, while
• Annex IV apply only to medical and monitoring equipment.

⏳ Duration & Renewal Timelines

• 5 years: Categories 1–7, 10 & 11
• 7 years: Categories 8 & 9
• Renewal applications must be filed 18 months before expiry.
• Commission decisions must be issued 6 months before expiry.
• Rejections take effect 12–18 months after decision, allowing industry time to adapt.

If there is no 18-month gap between a decision and expiry, no renewal can be filed —the exemption expires permanently.

🏛️ 1 | Lead in Steel, Aluminium & Copper (Entry 6)

⚠️ These exemptions do not cover products accessible to children (< 5 cm dimension) unless lead release ≤ 0.05 µg/cm²·h for ≥ 2 years.

⚙️ 2 | Lead in High-Melting-Point Solders (Entry 7(a))

💡 These remain valid until end of 2027—manufacturers can still apply for renewal.

🔬 3 | Lead in Glass & Ceramic Components (Entry 7(c))

📅 Which Exemptions Have Expired Forever?

Based on the 2025 directives and ComplyMarket analysis, the following have expired with no renewal option:

• 6(a) – Lead in steel for machining & galvanised steel
• 6(b) – Lead in aluminium (all general categories)
• 6(b)-I – Recycled aluminium (except cats 9 & 11)
• 6(b)-II – Machining aluminium (except cats 9 & 11)

All other entries remain eligible for renewal until 2027 if applications are submitted on time.

🧠 How to Renew Your Exemption Efficiently

Preparing a technical justification for exemption renewal can be complex—requiring evidence of substitution difficulty, availability of alternatives, and environmental impact assessment.

ComplyMarket’s AI-powered RoHS Extension Application Tool automates this process:

• Enter company name and contact info
• Describe product and RoHS category
• Identify components and exemption number
• Generate a ready-to-submit application within minutes

Once completed, applications should be sent via email to ENV-ROHS@ec.europa.eu and by post to:

European Commission – DG Environment
Unit ENV/A2 – Waste Management & Recycling
Avenue de Beaulieu 9 (BU9 5/1-6)
B-1160 Brussels, Belgium

🚀 Conclusion — Strategic Action for 2026 & 2027

The 2025 EU RoHS amendments mark a significant turning point toward a lead-free, circular electronics economy.
While some legacy exemptions have expired forever, most remain renewable until mid-2027.
Manufacturers should now focus on:

1. Identifying components using entries 6(a)–7(c)
2. Submitting renewal requests by late 2025 or early 2026
3. Updating declarations of conformity and supplier data
4. Monitoring new Commission rolling plans (Annex III & IV 2026 update expected Q3 2026)

ComplyMarket continues to support industry with automated compliance tools and training for the next generation of product stewardship.