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    EU RoHS

    July 23, 2026 | Written by GreenSoft Technology, Inc.

    New EU RoHS Exemption Renewal Decisions published for Lead and Cadmium in Electronics

     

    Draft EU RoHS Exemption Renewals Published for Lead and Cadmium Uses

    On July 8, the European Commission published a draft delegated directive in response to industry renewal requests for several EU RoHS Annex III and IV exemptions.

    These exemptions cover a wide range of specialized applications where technically viable substitutes for lead or cadmium are not yet available. Common examples include optical glass, fluorescent lamp components, ceramic capacitors, laser assemblies, and medical phototherapy equipment.

    The draft proposal is currently open for public consultation as part of the EU's Better Regulation process. Stakeholders have until August 5, 2026 to provide comments on the proposed changes before the Commission finalizes and adopts the delegated directive. Companies that may be impacted by these exemptions can submit observations through the European Commission’s consultation portal here.

    For manufacturers, keeping pace with evolving EU RoHS exemptions can be challenging, particularly when exemptions are split into multiple application-specific entries with different scopes and expiration dates. GreenSoft Technology helps companies monitor regulatory developments, collect supplier material declarations, and maintain accurate compliance data so they can quickly assess whether exemption changes affect their products and supply chains.

    Summary of the Latest Exemption Updates

    The proposed delegated directive renews many existing exemptions while also introducing several new application-specific exemptions and restructuring others. In some cases, existing broad exemptions would be replaced by narrower exemptions targeted at specific technologies or end uses.

    Key Takeaways

    • 14 Annex III exemptions are proposed for renewal or restructuring.
    • Several broad exemptions would be split into more narrowly defined application-specific exemptions.
    • Proposed validity periods range from 12 to 54 months depending on the application.
    • Significant Annex IV restructuring is proposed for oxygen sensors, medical equipment, laser systems, MRI/NMR technologies, and SQUID detectors.
    • Public comments are being accepted through August 5, 2026.

    The tables below summarize the Annex III and Annex IV exemptions included in the draft proposal.

    In Annex III, points 5(b), 13(a), 13(b), 13(b)-(I), 13(b)-(II), 13(b)-(III), 18(b), 18(b)-I, 24, 29, 32, and 34 are proposed to be replaced by the following:

    Exemption

    Description

    Proposed Expiry

    5(b)

    Lead (not intentionally added) in soda lime glass used in the glass tube of fluorescent lamps, not exceeding 0.2% by weight

    Expires on [same day as date of entry into force plus 30 months] for category 5

    13(a)

    Lead in white glasses used for optical applications (excluding applications falling under any of points 13(b) to 13(b)-V of this Annex)

    Expires on [same day as date of entry into force plus 30 months] for categories 3, 4, 6, 7, 8, 9 and 11

    13(b)

    Cadmium and lead used in filter glasses and glasses for reflectance standards

    Expires on [same day as date of entry into force plus 12 months] for categories 8, 9 and 11

    13(b)-I

    Lead in ion coloured optical filter glass types

    Expires on [same day as date of entry into force plus 30 months] for all categories

    13(b)-II

    Cadmium in striking optical filter glass types; excluding applications falling under point 39(a) of this Annex

    Expires on [same day as date of entry into force plus 30 months] for all categories

    13(b)-III

    Cadmium and lead in glazes used for reflectance standards

    Expires on [same day as date of entry into force plus 12 months] for categories 1 to 7 and 10

    13(b)-IV

    Cadmium in glazes used for reflectance standards

    Expires on [same day as date of entry into force plus 30 months] for categories 8 and 9

    13(b)-V

    Lead compound coatings in infrared interference filters used in infrared gas analysis and mid-far-infrared spectroscopy

    Expires on [same day as date of entry into force plus 30 months] for category 9 industrial monitoring and control instruments

    18(b)

    Lead as activator in the fluorescent powder (1% lead by weight or less) of discharge lamps when used as sun tanning lamps containing phosphors such as BSP (BaSi₂O₅:Pb)

    Expires on [same day as date of entry into force plus 54 months] for categories 5, 8, 9 and 11

    18(b)-I

    Lead as activator in the fluorescent powder (1% lead by weight or less) of discharge lamps containing phosphors such as BSP (BaSi₂O₅:Pb) when used in medical phototherapy equipment

    Applies to categories 5 and 8 and expires on [same day as date of entry into force plus 12 months]

    18(b)-II

    Lead as activator in the fluorescent powder (1% lead by weight or less) of discharge lamps containing phosphors such as BSP (BaSi₂O₅:Pb) when used in medical phototherapy equipment, including extracorporeal photopheresis lamps

    Expires on [same day as date of entry into force plus 54 months] for categories 5, 8 and 9

    24

    Lead in solders for the soldering to machined through-hole discoidal and planar array ceramic multilayer capacitors

    Expires on [same day as date of entry into force plus 18 months] for all categories

    24(a)

    Lead in alloys used for soldering to through-hole discoidal and/or planar array ceramic multilayer capacitors:

    i) Not exceeding 50% lead by weight for applications where the components are mechanically mounted (e.g. by bolts, clips or screws) or bonded by a selective soldering/welding process and where the component will not exceed a temperature of 150°C.

    ii) In high melting point solders containing ≥85% lead by weight for cases where the components are mounted using an elevated temperature process (e.g. solder reflow, welding) at a temperature of ≥150°C or where the component is rated to operate at a temperature of ≥150°C.

    Expires on [same day as date of entry into force plus 54 months] for all categories

    29

    Lead bound in crystal glass as defined in Annex I (Categories 1, 2, 3 and 4) of Council Directive 69/493/EEC

    Expires on [same day as date of entry into force plus 30 months] for categories 3, 4, 5 and 11

    32

    Lead oxide in glass frit used as a sealing material for making window assemblies for argon and/or krypton laser tubes

    Expires on [same day as date of entry into force plus 30 months] for categories 6, 8, 9 and 11

    34

    Lead in cermet-based trimmer potentiometer elements

    Expires on [same day as date of entry into force plus 30 months] for all categories

     

    In Annex IV, points 1(b), 4, 9, 11, 12, and 34 are proposed to be replaced by the following:

    Exemption

    Description

    Proposed Expiry

    1(b)

    Lead anodes in electrochemical oxygen sensors.


    Expires on [same day as date of entry into force plus 12 months].

    1(b)-I

    Lead anodes in electrochemical sensors that measure oxygen concentrations of inhaled and/or exhaled air for patients and that are consumables in medical devices placed on the market before 26 May 2024.

    Expires on [same day as date of entry into force plus 54 months] for category 8 medical devices other than in-vitro diagnostic medical devices.

    1(b)-II

    Lead in galvanic oxygen sensors in instruments that are designed for the measurement of dissolved oxygen in concentrations below 30 ppb.

    Expires on [same day as date of entry into force plus 54 months] for category 8 medical devices other than in-vitro diagnostic medical devices.

    1(b)-III

    Lead anodes in galvanic capillary oxygen sensors in instruments that are designed for the measurement of oxygen in gases.

    Expires on [same day as date of entry into force plus 54 months] for category 9 industrial monitoring and control instruments.

    1(b)-IV

    Lead anodes in galvanic Hersch cells for oxygen sensors where sensitivity below 100 ppm is required.

    Expires on [same day as date of entry into force plus 54 months] for category 9 industrial monitoring and control instruments.

    1(b)-V

    Cadmium anodes in Hersch cells for oxygen sensors where sensitivity below 100 ppm is required.

    Expires on [same day as date of entry into force plus 78 months] for category 9.

    1(b)-VI

    Lead anodes in galvanic permeable membrane oxygen sensors in instruments that are designed for the measurement of oxygen in gases.

    Expires on [same day as date of entry into force plus 54 months] for category 9 industrial monitoring and control instruments.

    4

    Lead in glass frit of X-ray tubes and image intensifiers and lead in glass frit binder for assembly of gas lasers and for vacuum tubes that convert electromagnetic radiation into electrons.

    Expires on [same day as date of entry into force plus 12 months] for categories 8 and 9.

    4(a)

    Lead in glass frit binders for assembly of HeNe gas lasers used in heterodyne interferometry calibration and heterodyne interferometry positioning applications

    Expires on [same day as date of entry into force plus 30 months] for category 9 industrial monitoring and control instruments.

    9

    Cadmium in helium-cadmium lasers.

    Expires on [same day as date of entry into force plus 12 months] for category 9.

    9(a)

    Cadmium in helium-cadmium lasers of Raman spectrometers for stress measurement in semiconductors.

    Expires on [same day as date of entry into force plus 30 months] for category 9 industrial monitoring and control instruments.

    11

    Lead in alloys as a superconductor and thermal conductor in magnetic resonance imaging (MRI).

    Expires on [same day as date of entry into force plus 12 months].

    11(a)

    Lead in alloys as a superconductor in MRI devices and nuclear magnetic resonance (NMR) devices.'

    Expires on [same day as date of entry into force plus 78 months].

    12

    Lead and cadmium in metallic bonds creating superconducting magnetic circuits in MRI, SQUID, NMR (Nuclear Magnetic Resonance) or FTMS (Fourier Transform Mass Spectrometer) detectors.

    Expires on [same day as date of entry into force plus 12 months].

    12(a)

    Lead in metallic bonds creating superconducting electric circuits in superconducting quantum interference device (SQUID) detectors.

    Expires on [same day as date of entry into force plus 78 months].

    34

    Lead as an activator in the fluorescent powder of discharge lamps when used for extracorporeal photopheresis lamps containing BSP (BaSi2O5:Pb) phosphors.

    Expires on [same day as date of entry into force plus 12 months].

     

    According to the European Commission , these changes are intended to better reflect the availability of substitute technologies and make future exemption reviews more technology-specific. Manufacturers of medical devices and industrial monitoring equipment should review the proposed Annex IV revisions carefully to determine whether their products remain covered under the new exemption structure.

    Stay Ahead of Changing EU RoHS Requirements

    The proposed exemptions outlined above are still subject to review and may change before the final directive is adopted. However, manufacturers that rely on lead- or cadmium-based exemption coverage should begin evaluating the potential impact of these proposed changes now.

    How GreenSoft Technology Helps

    • Regulatory Monitoring: Stay informed of new exemption proposals, renewals, and expirations that could affect your products.
    • Supplier Data Collection: We work directly with suppliers to obtain the latest material declaration and substance compliance information.
    • Product Impact Analysis: Quickly identify parts and assemblies that rely on specific EU RoHS exemptions.
    • GreenData Manager (GDM) Software: Centralize compliance records, supplier documentation, and regulatory data in a single system.

    By combining accurate supplier data with ongoing regulatory monitoring, GreenSoft helps manufacturers reduce compliance risk and respond more effectively to evolving global substance regulations.

    Learn more about GreenSoft's compliance Data Services and GreenData Manager (GDM) software, or contact us to schedule a personalized demonstration.

     

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