On July 8, 2026, the European Commission published a draft delegated directive proposing to revise and update multiple lead and cadmium exemption entries in Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment (the RoHS Directive). A four-week public consultation has now officially opened, with a deadline of August 5, 2026. CIRS provides the following interpretation based on the draft content.
"Refined" Adjustments to Exemption Clauses
This draft covers the renewal, consolidation, splitting, or revocation of more than 20 exemption entries in Annex III and Annex IV, spanning multiple technical fields including fluorescent lamp glass tubes, optical filter glass, medical phototherapy equipment, ceramic capacitor solder, laser tubes, oxygen sensors, and MRI equipment.
Key Adjustments
- Lead in fluorescent lamp glass tubes (Entry 5(b)): Renewed but limited to lighting equipment categories only; not extended to new technologies such as LED. Lead is defined as "non-intentionally added" (impurity from recycled glass).
- Optical filter glass series (Entry 13(b)): Consolidated and refined; new exemption added for infrared interference filters; lead removed from reflectance standard glass, retaining only cadmium.
- Lead in medical phototherapy equipment: Two previously separate exemptions in Annex III and Annex IV are merged into a new Entry 18(b)-(II).
- Solder for ceramic capacitors (Entry 24(a)): Distinguishes between high-melting-point and low-melting-point solder, replacing the original broad Entry 24.
- Oxygen sensors (Entry 1(b)): Split into 6 sub-entries with differentiated validity periods for different technical routes; new cadmium exemption added for Hersch cell batteries.
- Lead/Cadmium in laser tubes (Entries 4(a), 9(a)): Scope narrowed to specific application scenarios.
Detailed Content
1. Annex III Revisions
|
Entry |
Substance |
Application |
Product Category |
Transition Period |
|
5(b) |
Lead (non-intentionally added) |
Soda-lime glass in fluorescent lamp tubes, lead ≤ 0.2% |
Category 5 |
Entry into force + 30 months |
|
13(a) |
Lead |
White glass for optical applications (excluding 13(b) series) |
Categories 3, 4, 6, 7, 8, 9, 11 |
Entry into force + 30 months |
|
13(b)-I |
Lead |
Ionically colored optical filter glass |
All categories |
Entry into force + 30 months |
|
13(b)-II |
Cadmium |
Color rendering optical filter glass |
All categories |
Entry into force + 30 months |
|
13(b)-IV |
Cadmium |
Reflectance standard glaze |
Categories 8, 9 |
Entry into force + 30 months |
|
13(b)-V |
Lead compound coating |
Infrared interference filters (infrared gas analysis / mid-to-far infrared spectroscopy) |
Category 9 |
Entry into force + 30 months |
|
18(b) |
Lead (activator, ≤ 1%) |
Fluorescent powder (BSP) in sunlamp discharge lamps |
Categories 5, 8, 9, 11 |
Entry into force + 54 months |
|
18(b)-II |
Lead (activator, ≤ 1%) |
Medical phototherapy equipment (including extracorporeal photochemotherapy lamps) |
Categories 5, 8, 9 |
Entry into force + 54 months |
|
24(a) |
Lead |
Solder alloys for ceramic multilayer capacitors (distinguishing LMP ≤ 50% and HMP ≥ 85%) |
All categories |
Entry into force + 54 months |
|
29 |
Lead (bound) |
Crystal glass |
Categories 3, 4, 5, 11 |
Entry into force + 30 months |
|
32 |
Lead oxide |
Sealing material for argon/krypton laser tube window assemblies |
Categories 6, 8, 9, 11 |
Entry into force + 30 months |
|
34 |
Lead |
Cermet trimmer potentiometer elements |
All categories |
Entry into force + 30 months |
2. Annex IV Revisions
|
Entry |
Substance |
Application |
Product Category |
Transition Period |
|
1(b)-I |
Lead (anode) |
Sensors measuring oxygen concentration in patient inhaled/exhaled air (placed on the market before May 26, 2026) |
Category 8 |
Entry into force + 54 months |
|
1(b)-II |
Lead |
Amperometric sensors measuring dissolved oxygen < 30 ppb |
Category 8 |
Entry into force + 54 months |
|
1(b)-III |
Lead (anode) |
Capillary oxygen sensors (oxygen measurement in gas) |
Category 9 |
Entry into force + 54 months |
|
1(b)-IV |
Lead (anode) |
Hersch cell oxygen sensors (sensitivity < 100 ppm) |
Category 9 |
Entry into force + 54 months |
|
1(b)-V |
Cadmium (anode) |
Hersch cell oxygen sensors (sensitivity < 100 ppm) |
Category 9 |
Entry into force + 78 months |
|
1(b)-VI |
Lead (anode) |
Oxygen-permeable membrane oxygen sensors (oxygen measurement in gas) |
Category 9 |
Entry into force + 54 months |
|
4(a) |
Lead |
HeNe gas laser glass frit (heterodyne interferometer calibration/positioning) |
Category 9 |
Entry into force + 30 months |
|
9(a) |
Cadmium |
Helium-cadmium lasers in Raman spectrometers (semiconductor stress measurement) |
Category 9 |
Entry into force + 30 months |
|
11(a) |
Lead |
Superconductor alloys in MRI and NMR equipment |
— |
Entry into force + 78 months |
|
12(a) |
Lead |
SQUID superconducting circuit metal bonds |
— |
Entry into force + 78 months |
ChemRadar Insights
Multiple existing exemptions for optical glass, sensors, laser tubes, capacitor solder, and medical imaging equipment have been assigned expiration dates ranging from 12 to 78 months. Companies must complete material substitution or product design changes within the transition periods. The refinement and shortening of exemption clauses mean supply chains need to be re-evaluated. Enterprises in the medical and industrial monitoring/control sectors, in particular, face EU market access risks if they fail to phase out restricted substances in time. Meanwhile, R&D and certification costs for alternative materials will rise significantly in the short term.
Further information
