The European RoHS Directive (2011/65/EU) restricts the use of certain hazardous substances in electrical and electronic equipment. These substances include lead (Pb), which is used as an alloying element in brass. Until now, exemption 6(c) has applied to certain applications. It allows up to 4% by weight of lead in copper alloys. The main reason for the exemption is its technical necessity. This has been reviewed and extended several times, as lead-free alternatives are available but are not equivalent in all applications.

With Delegated Directive (EU) 2025/2364, published on November 21, 2025, the European Commission set an end date for RoHS exemption 6c: June 30, 2027. The decision was published in the Official Journal and is therefore legally valid. An application for a further extension was submitted in December 2025. It is unclear whether this application will be granted, as the political will is clearly moving towards lead-free materials. Companies should therefore keep themselves regularly informed about the current legal situation and prepare for the changeover to lead-free products at an early stage.

According to current legislation, products containing lead will no longer be RoHS-compliant from July 1, 2027, and may therefore no longer be placed on the market in the EU. The decisive factor is the date of placing on the market, not the date of production. So don't wait until the last day. Start early by:

• Identifying affected components and assemblies.
• Planning the switch to lead-free together with your suppliers.
• Considering lead-free alternatives in new development projects.
• Monitoring stocks of lead-containing goods more closely.
• Planning resources for documentation (declarations of conformity and such).

This is the only way to develop sustainable solutions, achieve planning security in your supply chain, and bring RoHS-compliant products to market with confidence. Think about the life cycle of your products, which will be on the market well beyond 2027.