What Businesses Need to Know About Major Changes to RoHS Exemptions

Article Highlights:

• The Restriction of Hazardous Substances Directive, commonly known as RoHS, is the European Union regulation that restricts the use of specific hazardous substances in electrical and electronic equipment. While the directive generally prohibits the use of restricted substances above defined concentration thresholds, the RoHS Directive includes exemptions that permit restricted substances to remain in specific uses under certain defined conditions.
• As the European Commission reviews requests for renewals, amendments, and impending expirations, RoHS exemptions evolve. According to the current RoHS review plan, a significant number of exemptions are either approaching their expiration dates, under evaluation, or awaiting final renewal decisions.
• Companies that proactively monitor exemption updates, engage suppliers effectively, and leverage RoHS compliance software will be better positioned to maintain compliance. RoHS compliance software like Z2 provides organizations with a scalable way to manage compliance risks. 

For many manufacturers, RoHS compliance is often viewed as a straightforward exercise: they need to restrict specific substances in their production processes, including lead, mercury, and cadmium. One of the most complex aspects of the RoHS Directive, however, is not the substance restrictions themselves, but the exemptions that allow certain restricted substances to remain in use. (Specifically, in certain applications where suitable alternatives are not yet technically or scientifically feasible.)

But while they might offer valuable reprieves to some businesses, these exemptions are not permanent. The European Union regularly reviews, renews, and ends RoHS exemptions as technology evolves and safer alternatives become available. As a result, manufacturers that rely on exemption coverage today may find that the same products become noncompliant tomorrow—or at least in the near future. 

The growing pace of exemption reviews is creating significant compliance challenges across global supply chains. And the consequences are tangible and near at hand: 

• Engineering teams forced to redesign products.
• Procurement teams under pressure to source alternative components. 
• Suppliers needing to provide updated compliance documentation. 
• Product compliance professionals continuously monitoring regulatory developments to ensure products remain compliant in the European Union.

The challenge becomes even greater when organizations manage thousands of parts, hundreds of suppliers, and numerous product families. In this environment, RoHS compliance tools are becoming essential for monitoring exemption changes, maintaining supplier documentation, and reducing compliance risk.

The challenge becomes even greater when organizations manage thousands of parts, hundreds of suppliers, and numerous product families.

What Are RoHS Exemptions?

The Restriction of Hazardous Substances Directive, commonly known as RoHS, is the European Union regulation that restricts the use of specific hazardous substances in electrical and electronic equipment. While the directive generally prohibits the use of restricted substances above defined concentration thresholds, regulators recognize that certain applications currently lack viable alternatives. To address this reality, the RoHS Directive includes exemptions that permit restricted substances to remain in specific uses under certain defined conditions.

RoHS exemptions cover a wide range of applications across numerous industries. Common exemption categories include:

• Lead in solders as well as glass and ceramics.
• Mercury in lighting applications.
• Cadmium in certain specialized uses.
• Hexavalent chromium in specific corrosion protection systems. 

These exemptions exist because prohibiting the use of certain substances without viable alternatives available to manufacturers could compromise product performance, reliability, safety, or functionality. 

How Often Are RoHS Exemptions Reviewed?

Under the RoHS Directive, exemptions are periodically reviewed by the European Commission. During these reviews, regulators evaluate whether technically feasible and reliable alternatives have become available since they last reviewed the existing RoHS exemptions. If suitable substitutes have emerged during that time period, exemptions may be discontinued. If alternatives remain unavailable, on the other hand, exemptions are often renewed, sometimes with revised expiration dates.

This means that the exemption status of a certain product or part should never be taken for granted or treated as permanent. Businesses must continuously monitor regulatory developments to understand how the EU’s compliance decisions might affect their products and their legal status. 

Which RoHS Exemptions Are Changing in 2026?

As the European Commission reviews requests for renewals, amendments, and impending expirations, RoHS exemptions evolve. According to the current RoHS review plan, a significant number of exemptions are either approaching their expiration dates, under evaluation, or awaiting final renewal decisions.

Many of the most closely watched changes involve lead-related exemptions—exceptions that are widely used across the electronics industry. These include:

• Lead in solders with high melting temperature (Exemption 7(a))
• Lead in solders for servers, storage systems, network infrastructure equipment, and telecommunications applications (Exemption 7(c)-I)
• Lead in solders used in industrial monitoring and control instruments (Exemption 7(c)-II)
• Lead in dielectric ceramic materials used in capacitors and electronic components (Exemption 7(c)-IV).

Additional exemptions under active review include several applications covered by Exemption 6, which addresses lead as an alloying element in steel, aluminum, and copper. In addition, exemptions within the scope of Exemption 15, including lead in solders used to complete viable electrical connections between semiconductor dies and carriers within integrated circuit packages, face the possibility of expiring. These exemptions are particularly important because they affect a broad range of electronic components used throughout global supply chains.

The lighting sector also continues to experience significant exemption activity:

• Multiple mercury-related exemptions under Exemption 4 are being phased out or reviewed, as LED technology increasingly replaces fluorescent and specialty lighting applications. 

Manufacturers of lighting products and equipment containing lamps should pay close attention to these developments, as several mercury exemptions have already expired or are scheduled for expiration.

Medical device and industrial equipment manufacturers face additional complexity because many category-specific exemptions have different validity periods than those applicable to consumer electronics. Several exemptions supporting specialized applications in these sectors remain under review, creating uncertainty for longer product lifecycle equipment.

A key challenge for manufacturers is that many exemptions remain in the review process beyond their original expiration dates (a period during which the European Commission continues to evaluate renewal requests). Although products may continue to rely on exemptions during these extended review periods, businesses cannot assume that renewals will be granted indefinitely or without changes to scope and applicability.

Organizations should regularly review the European Commission's exemption validity and rolling plan to identify exemptions that affect their products. Understanding which RoHS exemptions are approaching review milestones or expiration dates allows engineering, procurement, and compliance teams to assess potential impacts early and develop contingency plans before regulatory decisions affect product availability or market access.

Why Changes to RoHS Exemptions Matter for Manufacturers

When a RoHS exemption changes, the impact often extends far beyond a single business’s compliance department.

One of the most immediate concerns is that components previously considered compliant may no longer qualify for exemption coverage. If a component contains a restricted substance and the exemption supporting that use expires, the component may become noncompliant unless an alternative solution is quickly implemented.

When not proactively mitigated, this kind of development often triggers product redesigns. Engineering teams may need to evaluate substitute materials, alternative components, new manufacturing processes, or modified product architectures. And these changes can require extensive testing and validation before being fully implemented in factories. 

When RoHS exemptions expire, supplier documentation also becomes a critical issue. Existing supplier documents may become outdated if exemption references change. Manufacturers must obtain updated declarations, certificates, and material disclosures demonstrating continued compliance. 

Further, production disruptions can occur when approved components become unavailable or when replacement parts require lengthy qualification processes. Lead times may increase as manufacturers compete for alternative compliant components.

If a component contains a restricted substance and the exemption supporting that use expires, the component may become noncompliant unless an alternative solution is quickly implemented.

How RoHS Exemption Changes Impact Supply Chains

Component Obsolescence Risks

One of the largest business risks associated with exemption changes is component obsolescence. A component that relies on a substance that has been under a RoHS exemption that is now expiring will quickly become unusable in products sold into regulated markets. This can create significant inventory exposure, particularly for products with long development cycles or extended service life requirements. Manufacturers may find themselves forced to replace components that are entering EOL because their RoHS exemption expired, potentially driving up redesign costs and creating supply continuity concerns.

Supplier Qualification Challenges

When exemptions change, suppliers often need time to identify compliant alternatives, validate new materials, and update compliance documentation. Some suppliers respond quickly, while others struggle to keep pace with regulatory developments. This inconsistency creates risk throughout the supply chain. Organizations that source from these suppliers may need to requalify them, identify secondary sources, or conduct additional due diligence to ensure ongoing compliance.

Increased Compliance Verification Requirements

As exemptions evolve, compliance verification becomes more complex. Manufacturers must determine which components rely on exemptions, which exemptions still apply, when expiration dates occur, and whether the replacement materials have gone through all the required validation processes. This level of analysis becomes increasingly difficult when managing thousands of components across multiple product lines.

Customer Disclosure Requirements

Customers are increasingly requesting detailed compliance evidence, including exemption declarations and supporting documentation. When exemption statuses change, manufacturers may need to provide updated compliance reports, revised declarations, and evidence demonstrating compliance to their customers and other supply chain partners. Failure to respond promptly to these requests can impact customer confidence and create other commercial risks.

How RoHS Compliance Software Helps Businesses Manage Exemption Changes

Changes to RoHS exemptions are now a recurring compliance risk, one that affects procurement, engineering, product development, and regulatory teams alike. As these exemptions continue to come down the pike, organizations must maintain visibility into which products, components, and suppliers rely on those regulatory exceptions. Waiting until an exemption expires to take decisive action can result in a myriad of supply chain challenges, including redesign costs, production stoppages, documentation gaps, and other potential disruptions. 

Companies that proactively monitor exemption updates, engage suppliers effectively, and leverage RoHS compliance software will be better positioned to maintain compliance and avoid operational disruptions. RoHS compliance software like Z2 provides organizations with a scalable way to manage compliance risks—including expiring exemptions and the level of unpredictability they introduce into an organization’s risk management framework. 

Compliance platform Z2 works with companies to achieve compliance with over 180 global regulations that span chemical, product, trade, and ESG, including not only RoHS and REACH, but also EUDR, SCIP, California Proposition 65, PFAS, and many others. By partnering with Z2, businesses are able to:

• Understand their full regulatory data requirements.
• Rely on a team of experts to carry out supply chain due diligence.
• Participate in a full compliance risk analysis.
• Receive reports and declarations for all their compliance obligations.

To learn more about Z2Data’s compliance services, schedule a free trial with one of our product experts.