RoHS compliance rarely breaks down because companies are unaware that substances such as lead, cadmium, or mercury are restricted. Instead, problems usually arise quietly when the RoHS exemptions a company relies on expire, are narrowed, or are divided into new, more specific sub-exemptions. When that happens, certificates, technical files, and supplier declarations may no longer align with current legal requirements. As a result, maintaining compliance is not just about understanding which substances are restricted; it also requires actively monitoring the exemptions that temporarily permit their use and updating supporting evidence before expiry dates. With this in mind, this article groups RoHS exemptions into two categories—general exemptions under Annex III and medical/monitoring exemptions under Annex IV—and explains for each what is allowed, where it applies, and what manufacturers should do to avoid last-minute compliance issues.
General RoHS Exemptions (Annex III)
Annex III exemptions are EU-approved allowances that permit restricted substances—such as lead, mercury, cadmium, hexavalent chromium, PBB/PBDE, and certain phthalates—in specific applications when substitution is technically or scientifically impractical, or when replacement could introduce greater safety, reliability, or environmental risks. These exemptions are time-limited, regularly reviewed, and narrowly defined by application and product category.
6-Series: Lead in Metals
Lead exemptions in metals are widely used and often misunderstood, particularly because lead may be present intentionally for performance or machining reasons, or unintentionally due to recycled or scrap content. As the European Commission continues to refine exemption language and guidance, compliance expectations increasingly emphasize precision. Companies must clearly justify why lead is present and reference the exact applicable sub-exemption rather than relying on outdated or overly broad claims.
6a series: Lead in steel + galvanised steel
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6(a): Lead in steel for machining and in galvanized steel
Lead as an alloying element in steel for machining purposes and in galvanized steel containing up to 0.35% Pb by weight.
Applies to: All categories
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6(a)-II: Lead in batch hot-dip galvanised steel components
Lead as an alloying element in batch hot-dip galvanised steel components containing up to 0.2% Pb by weight.
Applies to: All categories
6b series: Lead in aluminium alloys (umbrella + scrap + machining + casting)
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6(b): Lead in aluminium alloys (general umbrella)
Lead as an alloying element in aluminium, containing up to 0.4% Pb by weight.
Applies to: All categories
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6(b)-I: Lead in aluminium from recycled lead-bearing scrap
Lead as an alloying element in aluminium up to 0.4% Pb by weight, provided it stems from lead-bearing aluminium scrap recycling.
Applies to/expiry:
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Categories 1–7 and 10: expires 11 Dec 2026
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Categories 9 and 11 (other EEE): expires 11 Jun 2027
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6(b)-II: Lead in aluminium for machining purposes
Lead as an alloying element in aluminium for machining purposes with a lead content up to 0.4% Pb by weight.
Applies to / expiry:
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Categories 1–7 and 10: expires 11 Jun 2027
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Category 9: expires 30 Jun 2027
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6(b)-III: Aluminium casting alloys from scrap (lower cap)
Lead as an alloying element in aluminium casting alloys containing up to 0.3% Pb by weight, provided it stems from lead-bearing aluminium scrap recycling.
Applies to: Categories 1–7, 8, 9 other than in industrial, and 10.
7-Series: Lead in Solders and in Glass/Ceramics
The 7-Series RoHS exemptions cover specific cases where lead is still allowed in solder alloys and in certain glass/ceramic materials—typically because it’s needed to ensure reliability, high-temperature performance, electrical functionality, or long-term durability where viable lead-free alternatives aren’t yet feasible.
7a series: Lead in high melting temperature type solders (≥ 85% Pb)
These 7a sub-exemptions are crucial because they split “high melting solder” into function-specific use cases. Therefore, your evidence must connect the exemption to the exact function and assembly context.
Scope for all 7a entries: Applies to all categories except applications covered by point 24 of this Annex.
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7a-I: Semiconductor die attach/internal interconnections
Internal interconnections for attaching die (or components with a die) in semiconductor assembly with steady state or transient/impulse currents ≥ 0.1 A or blocking voltages beyond 10 V, or die edge sizes larger than 0.3 mm × 0.3 mm.
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7a-II: Die attach connections meeting conductivity/solidus conditions
Integral (internal and external) die-attach connections, if all conditions are met:
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thermal conductivity > 35 W/(m × K)
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electrical conductivity > 4.7 MS/m
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solidus melting temperature > 260 °C
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7a-III: First level solder joints to prevent reflow
First level solder joints so that subsequent mounting with a secondary solder does not reflow the first level solder; excludes die attach applications and hermetic sealings.
Also added following RoHS Exemptions:
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7a-IV: Second level solder joints (ceramic BGA / over moulding)
Second level joints for attachment to PCB/lead frames:
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solder balls for ceramic BGA attachment
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high temperature plastic overmouldings (> 220 °C)
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7a-V: Hermetic sealing material
Hermetic sealing between (1) ceramic package/plug and metal case; (2) component terminations and an internal sub-part.
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7a-VI: Electrical connections in specific lamp types
Electrical connections between lamp components in incandescent reflector lamps for infrared heating, high intensity discharge lamps, or oven lamps.
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7a-VII: Audio transducers at peak temperature > 200 °C
Audio transducers where peak operating temperature exceeds 200 °C.
7(c) split: Lead in glass vs lead in ceramics - RoHS Exemptions
Historically, many companies cited “7(c)” broadly. However, the refined split reflects functional differences. As a result, audits increasingly expect the most accurate sub-entry, not a blanket claim.
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7(c)-V — Lead in glass or glass matrix compound (function-specific)
Components containing lead in glass/glass matrix compound for one of these functions:
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protection/electrical insulation in glass beads of high-voltage diodes and glass layers for wafers
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hermetic sealing between ceramic, metal and/or glass parts
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bonding in a process window < 500 °C with viscosity 10¹³.³ dPas
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resistive ink (1 ohm/square to 100 megohm/square), excluding trimmer potentiometers
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chemically modified glass surfaces for MCPs, CEMs, and RGPs
Applies to: All categories.
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7(c)-VI — Lead in ceramic applications (PZT, PTC)
Components containing lead in a ceramic for: (1) PZT piezoelectric ceramics; (2) PTC ceramics.
Applies to: All categories.
9-Series of RoHS Exemptions
9a-III: Hexavalent chromium in sealed circuit working fluid (gas absorption heat pumps)
Up to 0.7% hexavalent chromium by weight used as an anticorrosion agent in the working fluid of the carbon steel sealed circuit of gas absorption heat pumps for space and water heating.
Applies to: Category 1 (Large household appliances).
4-Series of RoHS Exemptions
4(b): Mercury in High Pressure Sodium (vapour) lamps (Ra > 80)
Up to 16 mg of mercury per burner may be used in high pressure sodium (vapour) lamps for general lighting purposes with improved colour rendering index (Ra > 80), for P ≤ 105 W.
Applies to: Category 5 (Lighting equipment)
39-Series: Cadmium Quantum Dots under RoHS Exemptions
39(a) : Cadmium selenide quantum dots in display lighting (Annex III)
Cadmium selenide in downshifting cadmium-based semiconductor nanocrystal quantum dots for use in display lighting applications (< 0.2 μg Cd per mm² of display screen area).
Applies to: Categories 1 to 11
39(b) : Quantum dots directly deposited on LED chips for display/projection (Annex III)
Cadmium in downshifting semiconductor nanocrystal quantum dots directly deposited on LED semiconductor chips for use in display and projection applications (< 5 μg Cd per mm² of LED chip surface), with a maximum amount per device of 1 mg.
Applies to: Categories 1 to 11 (other EEE)
Medical / Monitoring RoHS Exemptions (Annex IV)
Medical devices and monitoring/control instruments often require higher reliability and longer qualification cycles. Therefore, Annex IV exemptions are narrower and more use-case driven. In turn, audits typically expect stronger justification tying the exemption to the actual application and field conditions.
27: Lead in solders/connectors near MRI or particle therapy magnet fields
Lead in solders, termination coatings, PCB solders, wire connections, shields and enclosed connectors used in:
(a) magnetic fields within a 1 m radius around the isocenter of MRI magnets (including monitors used within this sphere), or
(b) magnetic fields within 1 m of external surfaces of cyclotron magnets / beam transport magnets for particle therapy.
Applies to: Categories 8 and 9
37: Lead in platinised platinum electrodes for conductivity measurements
44: Cadmium in radiation tolerant video camera tubes (high radiation environments)
Cadmium in radiation tolerant video camera tubes designed for cameras with centre resolution > 450 TV lines used in environments with ionising radiation exposure exceeding 100 Gy/hour and total dose > 100 kG.
Applies to: Category 8 (other than in vitro diagnostic) and 9
48: Lead in superconducting cables (BSCCO) and their connections
Lead in BSCCO superconductor cables and wires, and lead in electrical connections to these wires.
Applies to: Categories 1 to 11
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EU RoHS Exemptions Update List |
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Exemption # |
Description |
Scope and Expiration Dates (if any) |
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4b |
Mercury in High Pressure Sodium (vapour) lamps for general lighting purposes not exceeding (per burner) in lamps with improved colour rendering index Ra > 80: P ≤ 105 W: 16 mg may be used per burner |
Applied to category 5 - Lighting equipment |
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6a |
Lead as an alloying element in steel for machining purposes and in galvanized steel containing up to 0,35 % lead by weight. |
Applies to all categories |
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6a-II |
Lead as an alloying element in batch hot-dip galvanised steel components containing up to 0,2 % lead by weight. |
Applies to all categories |
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6b |
Lead as an alloying element in aluminium containing up to 0,4 % lead by weight. |
Applies to all categories |
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6b-I |
Lead as an alloying element in aluminium containing up to 0,4 % lead by weight, provided it stems from lead-bearing aluminium scrap recycling. |
1. Applies to categories 1 to 7, and 10 |
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6b-II |
Lead as an alloying element in aluminium for machining purposes with a lead content up to 0,4 % by weight. |
Applies to all categories |
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6b-III |
Lead as an alloying element in aluminium casting alloys containing up to 0,3 % lead by weight provided it stems from lead-bearing aluminium scrap recycling. |
Applies to categories 1 to 7, 8, 9 other than industrial, and 10 |
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7a-I |
Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead). |
Applies to all categories except applications covered by point 24 of this Annex |
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7a-II |
Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead). |
Applies to all categories except applications covered by point 24 of this Annex |
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7a-III |
Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead). |
Applies to all categories except applications covered by point 24 of this Annex |
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7a-IV |
Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead). |
Applies to all categories except applications covered by point 24 of this Annex |
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7a-V |
Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead). |
Applies to all categories except applications covered by point 24 of this Annex |
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7a-VI |
Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead). |
Applies to all categories except applications covered by point 24 of this Annex |
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7a-VII |
Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead) |
Applies to all categories except applications covered by point 24 of this Annex |
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7c-V |
Electrical and electronic components containing lead in a glass or glass matrix compound that fulfils any of the following functions: |
Applies to all categories |
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7c-VI |
Electrical and electronic components containing lead in a ceramic that fulfils any of the following functions: |
Applies to all categories |
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9a-III |
Up to 0,7 % hexavalent chromium by weight, used as an anticorrosion agent in the working fluid of the carbon steel sealed circuit of gas absorption heat pumps for space and water heating. |
Applies to category 1 - Large household appliances |
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39a |
Cadmium selenide in downshifting cadmium based semiconductor nanocrystal quantum dots for use in display |
Expired on November 21, 2025 |
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39b |
Cadmium in downshifting semiconductor nanocrystal quantum dots directly deposited on LED semiconductor chips for use in display and projection applications (< 5 μg Cd per mm2 of LED chip surface) with a maximum amount per device of 1 mg. |
Applies to categories 1 to 11 other EEE |
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27 (Annex IV) |
Lead in solders, termination coatings of electrical and electronic components and printed circuit boards, connections of electrical wires, shields and enclosed connectors, which are used in (a) magnetic fields within the sphere of 1 m radius around the isocenter of the magnet in medical magnetic resonance imaging equipment, including patient monitors designed to be used within this sphere, or (b) magnetic fields within 1 m distance from the external surfaces of cyclotron magnets, magnets for beam transport and beam direction control applied for particle therapy. |
Applies to categories 8 and 9 |
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37 (Annex IV) |
Lead in platinized platinum electrodes used for conductivity measurements where at least one of the following conditions applies: (a) wide-range measurements with a conductivity range covering more than 1 order of magnitude (e.g. range between 0,1 mS/m and 5 mS/m) in laboratory applications for unknown concentrations; (b) measurements of solutions where an accuracy of +/C 1 % of the sample range and where high corrosion resistance of the electrode are required for any of the following: (i) solutions with an acidity < pH 1; (ii) solutions with an alkalinity > pH 13; (iii) corrosive solutions containing halogen gas; (c) measurements of conductivities above 100 mS/m that must be performed with portable instruments. |
Expired on 31 December 2025 |
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44 (Annex IV) |
Cadmium in radiation tolerant video camera tubes designed for cameras with a centre resolution greater than 450 TV lines which are used in environments with ionising radiation exposure exceeding 100 Gy/hour and a total dose in excess of 100kGy. |
Applies to categories 8 other than in vitro diagnostic medical devices and 9 |
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48 (Annex IV) |
Lead in bismuth strontium calcium copper oxide (BSCCO) superconductor cables and wires and lead in electrical connections to these wires |
Applies to categories 1 to 11 |
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