RoHS Exemptions - Q4 2026

Exemptions Expiring in Q4 2026

A regulatory deadline can do more than trigger a paperwork exercise. It can affect component selection, product qualification, supplier contracts, manufacturing continuity and access to the EU market.

For electronics and industrial manufacturers,the final quarter of 2026 brings a series of important regulatory milestones. RoHS exemption expiries could force material reviews and redesign decisions. The challenge is identifying products, materials, suppliers and operations at risk, while preventing business disruptions.

This article highlights the critical dates,explains where the impact may fall and identifies the actions manufacturers should prioritize.

RoHS Exemptions : Dates and Limits

Component Redesign

For manufacturers relying on lead-bearing alloys, the first question is straightforward:

Which products depend on an exemption that is approaching expiry, and what happens if that exemption is no longer available?

Commission Delegated Directive (EU) 2025/2364revises exemptions covering lead in steel, aluminum and copper alloys. The implications can extend from electronic components to industrial instruments,monitoring and control equipment and wider manufacturing supply chains.

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Three Things to Remember

•     Do not confuse similar exemption numbers. Exemption 6(b)-I retains a 0.4% limit for specified recycled aluminum, while6(b)-III covers specified recycled-scrap aluminum casting alloys at 0.3%.

•     Category-specific dates matter. An exemption may expire earlier for some equipment categories than for others.

•     Do not treat exemptions 6(a), 6(a)-I and 6(a)-II as interchangeable. They cover different steel applications and have different expiry dates and scopes, so confirm the exact exemption applicable to each component.

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Additional Concerns

Check the specific exemption relied upon against other relevant amendments, including Commission Delegated Directive (EU) 2025/2363 on lead in glass or ceramic and Commission Delegated Directive (EU) 2025/1802 on lead in high-melting-temperature solders.

Article 5(5) of the RoHS Directive provides for continued validity while a qualifying renewal application is pending, where that mechanism applies. However, not all exemptions are renewable, and fixed transition periods must not be treated as eligible for extension. In particular, manufacturers should verify the applicable provisions for exemptions 6(a) and 6(b)-I before relying on any continued use after 11December 2026. Check the relevant amendment and any applicable Commission decision before making compliance or procurement decisions.

The directive also sets child safety conditions for specified exemptions, including 6(a)-I, 6(a)-II, 6(b)-I, 6(b)-II, 6(b)-III and 6(c)where applicable, equipment intended for supply to the general public must meet the specified lead-release and coating-durability criteria if the equipment or an accessible part could be placed in a child's mouth. The relevant lead-release limit is 0.05 μg/cm² per hour, and the coating must maintain the required performance for at least two years. The precise conditions in the directive determine applicability.

For this purpose, an item or accessible part is considered capable of being placed in a child's mouth if it is smaller than 5 cm in one dimension or has a detachable or protruding part of that size.

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What to Do Next

•     Map components to the exact RoHS exemption and equipment category.

•     Obtain current supplier declarations and material-composition evidence.

•     Start substitution, redesign or qualification where necessary.

•     Confirm renewal status before making procurement or compliance decisions.

•     Check other relevant RoHS amendments against the specific exemption relied upon.

Don't wait until an exemptions expires to investigate alternatives because it won't leave enough time for supplier qualifications, engineering validations, and production changes.

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Turn RoHS uncertainty into a clear action plan. Our RoHS assessment report reviews your product documentation, identifies compliance gaps, and prioritizes practical next steps—helping you address customer requests and reduce the risk of costly delays. Contact us today to scope your assessment.

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Get your BlueCircle RoHS Assessment Quote Today

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Links

RoHS:Commission Delegated Directive (EU) 2025/2364

RoHS:Commission Delegated Directive (EU) 2025/2363

RoHS:Commission Delegated Directive (EU) 2025/1802
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