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 Some exemptions have been revoked with a phase-out period of 12–18 months, while others have been renewed with a new expiry date of June 30, 2027, or December 31, 2027.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.

What is the EU Deforestation Regulation (EUDR) and why does it matter?

The EU Deforestation Regulation (EUDR) is a landmark law that prohibits products linked to deforestation from being sold in the EU. It requires manufacturers to perform due diligence to ensure products are:Free from deforestationCompliant with production country lawsSupported by a due diligence statementNon-compliance can result in product bans, legal penalties, and reputational damage, making EUDR adherence critical for companies exporting to or operating within the EU.

How does the EU Deforestation Regulation affect supply chain sustainability?

EUDR raises the bar on supply chain sustainability by mandating extensive data collection and annual risk assessments. Companies must analyze deforestation risk factors, such as land use, human rights concerns, and traceability to the origin plot. This marks a shift from basic compliance to ongoing, risk-informed due diligence, reshaping responsible sourcing standards.

What is a Digital Product Passport (DPP) and how does it support EUDR compliance?

A Digital Product Passport (DPP) is a digital record that contains detailed product information, including origin, materials, carbon footprint, and supplier data. While not mandatory under the EUDR, EU digital product passports streamline compliance by:Centralizing traceability dataEnabling faster, more accurate risk assessmentsSupporting proactive regulatory readinessAdopting DPPs gives manufacturers a scalable way to meet today’s EUDR requirements and prepare for future EU sustainability laws.

Which products are in scope under the EU Deforestation Regulation?

The EUDR applies to both raw commodities and derived goods, including:Commodities: Cattle, cocoa, coffee, oil palm, rubber, soy, woodProducts: Leather, chocolate, palm oil, glycerol, rubber items, pulp, paper goods

Why should manufacturers adopt Digital Product Passports now?

Proactively integrating digital product passports into compliance programs helps manufacturers:Stay ahead of evolving EU regulations like EUDR and the Ecodesign for Sustainable Products Regulation (ESPR)Increase transparency and audit readinessReduce manual compliance burdens and future proof their operationsWith global regulations trending toward stricter responsible sourcing requirements, DPPs are a strategic investment for long-term compliance and competitive advantage.