On September 8, 2025, the European Commission published a new delegated directive that revises the exemptions for lead as an alloying element in steel, aluminium, and copper. The aim is to align the RoHS Directive (2011/65/EU) with technological progress while maintaining a high level of environmental and health protection.

What Has Changed?

1. Restructuring of Exemptions

• The previous exemptions 6a (steel), 6b (aluminium), and 6c (copper) have been split into more specific sub-entries to better reflect their applications.
• This improves legal clarity and makes compliance easier to verify.

2. New Thresholds and Conditions

• Steel:
  • Two new exemptions: 6a-I (for machining purposes) and 6a-II (for hot-dip galvanized steel).
  • The lead limit for galvanized steel remains at 0.2% by weight.

• Aluminium:
  • New exemption 6b-III for recycled aluminium scrap, with a reduced lead limit of 0.3%.
  • The exemption for machining purposes will not be renewed – suitable substitutes are now available.

• Copper:
  • Exemption 6c remains in place, as reliable alternatives are still lacking.
  • The lead limit remains at 4%.

3. Unified Expiry Dates

• A single expiry date will apply to all categories of electrical and electronic equipment.
• Existing exemptions will expire 12 months after the new directive enters into force, unless a renewal is requested.

4. Restrictions for Consumer Products

• Products that could be mouthed by children are only exempt if:
  • the lead release rate is below 0.05 μg/cm²/h, and
  • the coating remains effective for at least two years under normal use.

What Does This Mean for Businesses?

• Review your supply chains: Are affected materials still compliant?
• Update technical documentation: Reflect new thresholds and exemptions.
• Track deadlines: Renewal applications must be submitted at least 18 months before expiry.
• Prepare for substitution: Especially for aluminium used in machining.

Conclusion: Time to Act

The updated directive brings greater clarity, but also greater responsibility. Companies that act early not only ensure regulatory compliance, but also gain a competitive edge through more sustainable product design.

👉 Tip: Now is the time to check whether your products still qualify under the new exemptions – and take action accordingly!

Do you or your employees need training on the RoHS Directive? You can find the next training dates here.

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