September 17, 2025

Expiring RoHS Exemptions – What Companies Need to Know

On September 8, 2025, the European Commission decided to let several exemptions under the RoHS Directive for the use of lead in alloys expire. For companies, this means one thing: act now to safeguard your market access in the EU.

Background: What is the RoHS Directive?

The RoHS Directive (2011/65/EU) – Restriction of Hazardous Substances – regulates the use of hazardous substances in electrical and electronic equipment. It prohibits the use of substances such as lead, mercury, cadmium, and hexavalent chromium in order to effectively protect human health and the environment.

However, certain exemptions applied in the past: in specific areas, the use of lead remained permitted – for example in steel, aluminum, and copper alloys. The reason: for many years, there were no technically mature and economically viable alternatives available for these applications.

What does “exemptions are expiring” mean?

With the Delegated Directive of the European Commission dated September 8, 2025, it is now clear: several of these exemptions will not be renewed.

In practice, this means:

After the deadlines, the affected materials may no longer be used.
Products that continue to contain lead alloys will lose their RoHS compliance.
Without compliance, these products can no longer be placed on the EU market.

When do the exemptions end?

According to the Delegated Directive of the European Commission (September 8, 2025), the following deadlines apply:

Note: Certain industrial applications (e.g., monitoring and control instruments) have extended transition periods, also ending on June 30, 2027.

All details can be found in the Annex of the Delegated Directive of the European Commission (Download PDF) and on the Commission’s website.

What does this mean for companies?

The end of exemptions brings significant pressure to act:

Check materials: Which products still contain lead alloys?
Adapt supply chains: Suppliers must provide lead-free alternatives in time.
Ensure compliance: From 2027 onward, only compliant products can be placed on the market.
Act early: Companies that start adjustments now avoid shortages and legal risks.

How Substantio supports you?

With Substantio, you are fully prepared:

Automated data checks: Substantio identifies where lead is still present in your bills of materials or product data.
Early-warning system: Get timely alerts when exemptions are about to expire.
Efficient supplier communication: Automatically request missing certificates or material data from your suppliers.
Comprehensive compliance: Beyond RoHS, Substantio also covers REACH, the Battery Regulation, and the Digital Product Passport

With Substantio, you are always prepared for regulatory changes – and secure your market access for the long term.

Are you prepared for the end of the RoHS exemptions?

Sources & Background Information

European Commission – Implementation of the RoHS Directive (2011/65/EU) Environment Website
Delegated Directive on expiring lead exemptions (September 2025) [EUR-Lex]
Delegated Directive of the European Commission as PDF download