Europe | Directive (EU) 2025/2364 Amending RoHS Directive on the Exemption for Lead as an Alloying Element in Steel, Aluminum and Copper

On November 21, the EU Commission published Directive (EU) 2025/2364 amending RoHS Directive on the exemption for lead as an alloying element in steel, aluminum, and copper.

Annex III to Directive 2011/65/EU is amended as follows:

6(a) - Lead as an alloying element in steel for machining purposes and in galvanized steel containing up to 0,35 % lead by weight.
- Expires on December 11, 2026.

6(a)-I - Lead as an alloying element in steel for machining purposes containing up to 0,35 % lead by weight (*).
- Expires on June 30, 2027 for all categories.

6(a)-II - Lead as an alloying element in batch hot-dip galvanized steel components containing up to 0,2 % lead by weight (*).
- Expires on June 30, 2027 for all categories.

6(b) - Lead as an alloying element in aluminum containing up to 0,4 % lead by weight.
- Expires on June 11, 2027.

6(b)-I - Lead as an alloying element in aluminum containing up to 0,4 % lead by weight, provided it stems from lead-bearing aluminum scrap recycling (*).
- Expires on December 11, 2026 for categories 1-7, 10.
- Expires on June 30, 2027 for categories 9 industrial monitoring and control instruments and 11.

6(b)-II - Lead as an alloying element in aluminum for machining purposes with a lead content up to 0,4 % by weight (*).
- Expires on June 11, 2027 for categories 1-7, 10. 
- Expires on June 30, 2027 for categories 9 industrial monitoring and control instruments and 11 (*).

6(b)-III - Lead as an alloying element in aluminum casting alloys containing up to 0,3 % lead by weight provided it stems from lead-bearing aluminum scrap recycling (*).
- Expires on June 30, 2027 for categories 1-8, 9 other than industrial monitoring and control instruments and 10.

6(c) - Copper alloy containing up to 4 % lead by weight (*).
- Expires on June 30, 2027.​

(*) The exemption shall not cover EEE for supply to the general public where the EEE or accessible part thereof may, during normal or foreseeable conditions of use, be placed in the mouth by children. However, the exemption shall apply where the following can be both demonstrated: 

- the rate of lead release from such an EEE or any accessible part, whether coated or uncoated, does not exceed 0,05 µg/cm² per hour (equivalent to 0,05 µg/g/h),

- for coated articles, that the coating is sufficient to ensure that this release rate is not exceeded for a period of at least two years of normal or reasonably foreseeable conditions of use of the EEE. 

For the purpose of this footnote, it is considered that an EEE or accessible part of an EEE may be placed in the mouth by children if it is smaller than 5 cm in one dimension or has a detachable or protruding part of that size.'.