What are the key changes to RoHS lead exemptions?

The European Commission has adopted delegated directives to revoke and renew key RoHS lead exemptions, including those for lead as an alloying element in steel, aluminum, and copper, lead in high melting temperature solder, and lead in glass or ceramic components. Some exemptions have been revoked with a phase-out period of 12–18 months, while others have been renewed with a new expiry date of June 30, 2027, or December 31, 2027. These changes could significantly impact global manufacturing supply chains.

Who is affected by these changes?

Any company placing electrical and electronic products, or their parts, on the market in the European Economic Area (EEA). Affected organizations, including suppliers, need to determine if lead is present in their products or parts and whether they will continue to need these exemptions. Time is limited to transition to lead-free parts or apply for the renewal of necessary exemptions.

What actions should companies take to comply with these new regulations?

Collaborate with suppliers to gain transparency into the use of lead in partsIdentify which exemptions are used in your supply chain for the use of leadEvaluate whether it’s feasible to transition to lead-free alternativesJoin trade associations or working groups to coordinate exemption renewal applications, especially for those expiring on June 30, 2027. Applications for these must be submitted by December 31, 2025.

Who is responsible for ensuring compliance with the EU RoHS Directive?

Compliance is the responsibility of manufacturers and importers of electrical and electronic equipment (EEE) into the EU. Manufacturers and importers must self-declare compliance and may face checks or market surveillance by EU member states. If found non-compliant, manufacturers and importers must demonstrate due diligence, including robust communication with suppliers and subcontractors to ensure compliance throughout the manufacturing process.

How can Assent’s EU RoHS solution support your proactive compliance efforts?

Assent’s EU RoHS solution provides tools to manage compliance, such as:Proactive notifications for RoHS exemption expirationsAutomated product declarations and BOM (bill of material) roll-upsReal-time reporting to monitor compliance statusThese features streamline the compliance process and help producers maintain a strong due diligence record.