On November 27, 2025, the EU Commission published Directive (EU) 2025/2364, updating several RoHS Annex III exemptions related to the use of lead in steel, aluminum, and copper.
The amendment introduces new sub-categories and sets final expiry dates between December 2026 and June 2027.
Main Updates
Steel:
Exemptions 6(a), 6(a)-I, 6(a)-II now expire between Dec 11, 2026 and Jun 30, 2027.
Aluminum:
Exemptions 6(b), 6(b)-I, 6(b)-II, 6(b)-III expire between Dec 11, 2026 and Jun 30, 2027, with deadlines varying by product category and recycled content.
Copper:
Exemption 6(c) (lead in copper alloys ≤ 4%) expires Jun 30, 2027.
Child Safety Restriction
Exemptions marked (*) do not apply to EEE that may be placed in children’s mouths, unless very low lead-release rates can be demonstrated and coating protection lasts at least two years.
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