On November 21, 2025, the European Union published three *Delegated Directives amending the lead-related exemption provisions of the *RoHS Directive (2011/65/EU). These amendments primarily address the use of lead in alloys, glass and ceramics, and *high-melting temperature type solders. These changes are expected to have a significant impact on manufacturers of electrical and electronic equipment (EEE). Therefore, companies are required to review material information and their supply chains to ensure continued regulatory compliance.
1. Delegated Directive: A legal act adopted by the European Commission to supplement a basic directive or amend its technical elements
2. RoHS: Restriction of the use of certain Hazardous Substances in electrical and electronic equipment
3. High-melting temperature type Solders: Solders with a high melting point that provide stable electrical connections in high-temperature environments
Publication: November 21, 2025
Entry into force: December 11, 2025
Deadline for transposition into national law by Member States: June 30, 2026
Original texts of the Delegated Directives
(EU) 2025/1802: Lead exemption for use in high-melting temperature solders
(EU) 2025/2363: Lead exemption for use in glass and ceramic components
(EU) 2025/2364: Lead exemption for use as an alloying element in steel, aluminium, and copper
Overview of EU RoHS
The EU RoHS Directive aims to reduce environmental pollution and risks to human health arising from the manufacture, use, and disposal of electrical and electronic equipment (EEE) by restricting hazardous substances contained in such products. Since its initial introduction in 2003, the Directive has undergone multiple revisions, resulting in an expansion of its scope, an increase in the number of restricted substances, and a strengthening of exemption provisions.
Scope of application (Article 2 & Annex I): Most electrical and electronic equipment, excluding products intended for specific uses such as military, aerospace, large-scale industrial installations, and certain medical applications.
Restricted substances (Annex II): Pb, Hg, Cd, Cr⁶⁺, PBB, PBDE, DEHP, BBP, DBP, and DIBP
Exemptions (Annex III): Exemptions are granted on a limited basis where the use of restricted substances is unavoidable or where technically feasible alternatives are not available
Key Changes Introduced by the EU RoHS Amendment
Following the completion of technical and scientific assessments of previously submitted exemption renewal applications, the existing exemption scopes have been further subdivided and the regulatory provisions clarified. As a result, certain exemption expiry dates have been revised and new exemption entries have been introduced. These amendments are intended to accelerate the transition to lead-free alternatives and are expected to have a direct impact across the entire electronics manufacturing supply chain, including machining and plating processes. In particular, the expiry of exemptions for machined aluminium components indicates that companies must urgently identify and validate alternative materials for application in future products. For detailed changes to each exemption entry, please refer to the attached document.
On November 21, 2025, the European Union published three *Delegated Directives amending the lead-related exemption provisions of the *RoHS Directive (2011/65/EU). These amendments primarily address the use of lead in alloys, glass and ceramics, and *high-melting temperature type solders. These changes are expected to have a significant impact on manufacturers of electrical and electronic equipment (EEE). Therefore, companies are required to review material information and their supply chains to ensure continued regulatory compliance.
1. Delegated Directive: A legal act adopted by the European Commission to supplement a basic directive or amend its technical elements
2. RoHS: Restriction of the use of certain Hazardous Substances in electrical and electronic equipment
3. High-melting temperature type Solders: Solders with a high melting point that provide stable electrical connections in high-temperature environments
Publication: November 21, 2025
Entry into force: December 11, 2025
Deadline for transposition into national law by Member States: June 30, 2026
Original texts of the Delegated Directives
(EU) 2025/1802: Lead exemption for use in high-melting temperature solders
(EU) 2025/2363: Lead exemption for use in glass and ceramic components
(EU) 2025/2364: Lead exemption for use as an alloying element in steel, aluminium, and copper
Overview of EU RoHS
The EU RoHS Directive aims to reduce environmental pollution and risks to human health arising from the manufacture, use, and disposal of electrical and electronic equipment (EEE) by restricting hazardous substances contained in such products. Since its initial introduction in 2003, the Directive has undergone multiple revisions, resulting in an expansion of its scope, an increase in the number of restricted substances, and a strengthening of exemption provisions.
Scope of application (Article 2 & Annex I): Most electrical and electronic equipment, excluding products intended for specific uses such as military, aerospace, large-scale industrial installations, and certain medical applications.
Restricted substances (Annex II): Pb, Hg, Cd, Cr⁶⁺, PBB, PBDE, DEHP, BBP, DBP, and DIBP
Exemptions (Annex III): Exemptions are granted on a limited basis where the use of restricted substances is unavoidable or where technically feasible alternatives are not available
Key Changes Introduced by the EU RoHS Amendment
Following the completion of technical and scientific assessments of previously submitted exemption renewal applications, the existing exemption scopes have been further subdivided and the regulatory provisions clarified. As a result, certain exemption expiry dates have been revised and new exemption entries have been introduced. These amendments are intended to accelerate the transition to lead-free alternatives and are expected to have a direct impact across the entire electronics manufacturing supply chain, including machining and plating processes. In particular, the expiry of exemptions for machined aluminium components indicates that companies must urgently identify and validate alternative materials for application in future products. For detailed changes to each exemption entry, please refer to the attached document.