On 21 November 2025, the European Commission published three long-awaited delegated directives in the Official Journal of the European Union.

These texts finally reshape how the RoHS Directive treats lead in alloys, solder joints, ceramics, and glass.

For years, manufacturers lived in a renewal limbo - same exemptions, same uncertainty, same dependencies on outdated materials. That era is officially over.

With the 2025 delegated acts, the Commission has split, narrowed, and time-boxed the major lead exemptions:

• Series 6 → lead in steel, aluminium, copper alloys
• 7a → high-melting-point solders
• 7c → lead in glass and ceramic components

The rules enter into force on 11 December 2025. And for the first time, Europe has put in place hard, non-negotiable expiration dates.

Let’s walk through what has changed.

Series 6: Lead in Alloys Finally Gets Hard Sunset Dates

Official source: Commission Delegated Directive (EU) 2025/2364

Series 6 used to be the easiest exemption to hide behind: “lead in steel up to 0.35%,” “lead in aluminium up to 0.4%,” “lead in copper alloys up to 4%.” Simple, broad, and exploited everywhere.

Now the Commission has split the scope and set two binding deadlines:

Expires on 11 December 2026

For general consumer categories (GC 1–7 and 10):

• 6a — lead in steel
• 6b-I — lead in aluminium (GC categories only)

If you’re in consumer electronics, home appliances, or IT equipment → your runway just shrank to 12 months.

Expires on 11 June 2027

For industrial and special categories (GK 9 and 11):

• 6b — lead in aluminium (general form)
• 6b-I (industrial) — for categories 9 and 11

Industrials get six extra months — but don’t let that fool you. Upstream alloy suppliers won’t wait until 2027 to phase materials out. They will switch to RoHS-compliant alloys as soon as GC markets transition, meaning supply pressure hits industrial users early.

Bottom line If you rely on castings, machined aluminium parts, connectors, fasteners, or structural components → start redesign now.

7a: High-Melting-Point Solders Are No Longer One Exemption — They’re Seven

Official source: Commission Delegated Directive (EU) 2025/1802

The original 7a exemption was a blanket clause for HMP solders (> 85% Pb). It became a catch-all, used in places it didn’t belong.

The Commission responded by doing the only logical thing: split it into seven clearly defined technical sub-entries with identical end-dates.

General 7a extension:

• 7a (generic) expires 30 June 2027

Then comes the real structure:

7a.I → chip-level internal connections

7a.II → high-performance die-attach (specific thermal & electrical thresholds)

7a.III → first-stage solder joints

7a.IV → second-stage BGA & high-temp molding applications

7a.V → hermetic sealing

7a.VI → special lamp applications

7a.VII → audio transducers >200 °C

Sub-entry expiry for all: 31 December 2027

This is the sunset window. After that, if an application doesn’t clearly meet one of these technical definitions → it becomes prohibited, even if the old 7a would have covered it.

The big implication: Engineers now need to know exactly what they’re using HMP solder for, not just “it’s legacy.” IEC 63000 files will require justification, datasheets, and thermal/electrical evidence.

7c: Lead in Glass and Ceramics Is Now Split Into Targeted Use-Cases

Official source: Commission Delegated Directive (EU) 2025/2363

Historically, 7c covered:

• lead in glass
• lead in ceramics
• lead in dielectric caps

All lumped in one bucket.

The Commission has now formalized a more modern structure:

➡ 7c.I — Generic glass/ceramic components

Expires 30 June 2027

This is the short bridging renewal. It’s intentionally temporary.

➡ 7c.II — Dielectric ceramic capacitors (≥125 VAC / ≥250 VDC)

Expires 31 December 2027

➡ 7c.V — Lead in glass matrix with defined functions

Includes:

• HV diode beads
• hermetic seals
• resistive inks
• microchannel plate glass Expires 31 December 2027

➡ 7c.VI — Lead-based ceramics for PZT & PTC functions

Expires 31 December 2027

These two new entries (V and VI) reflect the reality: some properties simply cannot be replicated by lead-free materials — yet.

But the sunset clock is still ticking.

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What This Means for Manufacturers

Let’s be blunt.

This is the first time in RoHS history that the Commission has:

• split all major lead exemptions
• set synchronized, non-extendable timelines
• pushed industry out of “pending renewal limbo”

And it changes your 2026–2027 operations in very real ways.

1. Every supplier declaration referencing old 6/7a/7c entries becomes outdated.

Expect a wave of non-conformities until new declarations arrive.

2. BoMs using lead-based alloys or ceramics must be re-classified under the new sub-entries.

No classification → no exemption → non-compliance.

3. IEC 63000 technical files need complete re-documentation.

Especially for:

• alloy substitutions
• HMP solder functional requirements
• PZT/ceramic justifications
• expiry date tracking

4. Upstream suppliers will transition BEFORE the official deadlines.

GC markets drive volume. Industrial users will see obsolescence early.

5. Redesign cycles have to start now.

A 12-month window is extremely tight for:

• validation
• mechanical redesign
• reliability testing
• regulatory review
• supplier qualification

Waiting until mid-2026 guarantees product delays.

Preparing for the 2026–2027 Lead Sunset

You don’t need a miracle. You need a system.

Here’s the approach that actually works:

Step 1 — Map every use of lead across your BoM

Categorize by:

• 6a, 6b, 6c
• 7a.I–VII
• 7c.I, II, V, VI

This is your control baseline.

Step 2 — Demand new supplier declarations (post-Dec 2025)

Outdated declarations are the #1 reason companies fail RoHS audits.

Step 3 — Identify high-risk components (GC categories first)

Consumer products hit the 12-month cliff immediately.

Step 4 — Begin material change projects for alloys and solder joints

Especially:

• aluminium castings
• structural parts
• connectors
• BGA assemblies
• PZT sensors
• high-voltage capacitors

Step 5 — Update IEC 63000 files with the new exemption logic

Regulators will target documentation gaps in 2026 and 2027.

Step 6 — Build a RoHS sunset dashboard

Categories, exemptions, expiry dates, evidence, and risk scoring. Exactly the kind of automated intelligence Acquis excels at.

The Bottom Line

RoHS has entered a new phase. The “renewal uncertainty era” is over. The Commission has moved to fixed timelines, tight technical definitions, and structured phase-outs.

Lead is on a countdown.

Not theoretical. Not pending. Dated. Binding. Live.

2026 and 2027 will be transition years where engineering, supply chain, compliance, and product teams finally need to converge — or face the reality of non-compliant components stopping shipments.