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News > EU RoHS Directives and Regulations > EU outsourced investigation agency publishes final report on RoHS Directive Pack 22 exemptions

EU outsourced investigation agency publishes final report on RoHS Directive Pack 22 exemptions

  • 2025-07-14

The German Institute for Applied Ecology (Oeko-Institut) released the final report of RoHS Pack 22 on January 13, 2022. The report evaluated and made recommendations on the extension applications for a total of nine exemption clauses in Annex III, namely 6(a), 6(a)-I, 6(b), 6(b)-I, 6(b)-II, 6(c), 7(a), 7(c)-I and 7(c)-II.

德國應用生態研究所 (Oeko-Institut) 於 2022 年 1 月 13 日發布 RoHS Pack 22 的最終報告,報告對附錄 III 中的 6(a), 6(a)-I, 6(b), 6(b)-I, 6(b)-II, 6(c), 7(a), 7(c)-I和7(c)-II 共計 9 項豁免條款的延期申請進行了評估並給出了建議。

On January 13, 2022, the final evaluation report for EU RoHS Investigation Pack 22 was officially released. The report evaluated and recommended extensions for nine exemptions in Annex III: 6(a), 6(a)-I, 6(b), 6(b)-I, 6(b)-II, 6(c), 7(a), 7(c)-I, and 7(c)-II. These exemptions cover a wide range of materials used in electrical and electronic products, including steel alloys, aluminum alloys, copper alloys, high-temperature solders, and glass and ceramics in electrical and electronic components. In addition, the report added five new exemptions: 6(a)-II, 6(b)-III, 6(b)-IV, 7(c)-V, and 7(c)-VI. The report also detailed seven application areas for 7(a) to help companies more effectively identify materials within the exemptions.

The terms and validity periods listed in the final assessment report are as follows:

Application for exemption extensionsuggestion
serial numberExemptionsExemptionsScope of application and expiration date
Annex III, 6(a) and 6(a)-ILead as an alloying element in steel for processing purposes and galvanized steel, with a content not exceeding 0.35%; Lead as an alloying element in steel for processing purposes, with a content not exceeding 0.35%; Lead content in batch hot dip galvanized steel does not exceed 0.2%6(a): Lead as an alloying element in steel for processing purposes up to a maximum of 0.35% and lead as an alloying element in galvanized steel for processing purposes up to a maximum of 0.35%In vitro diagnostic medical devices in category 8: July 21, 2023
Industrial monitoring and control equipment in category 9 and category 11: July 21, 2024
6(a)-I: Lead as an alloying element in steel for machining purposes, not exceeding 0.35%All categories: July 21, 2024
6(a)-II: Lead in hot dip galvanized steel not exceeding 0.2% in batchesAll categories: July 21, 2026
Annex III, 6(b) /6(b)-ILead is one of the alloying elements in aluminum alloys. The lead content does not exceed 0.4%. When the source is recycled lead-containing aluminum scrap, the lead content can be up to 0.4%.6(b)-I: When sourced from recycled leaded aluminum scrap, the lead content may be up to 0.4%All categories: 12 months after announcement
6(b)-III: When the source is recycled lead-containing aluminum scrap, the lead content of the cast aluminum alloy does not exceed 0.3%All categories: July 21, 2026
Annex III, 6(b)-IILead is used in aluminum alloys for processing purposes, with a lead content not exceeding 0.4%6(b)-II: Lead in aluminium alloys for machining purposes, with a lead content not exceeding 0.4%All categories: 18 months after announcement
6(b)-IV: Lead in aluminium alloys for machining purposes, in gas valves for use in Category 1 EEE (white goods) with a lead content not exceeding 0.4%2024 年 12 月 31 日
Annex III, 6(c)Lead in copper alloys not exceeding 4%6(c): Lead in copper alloys not exceeding 4%All categories: July 21, 2026
Annex III, 7(a)Lead in high melting point solders (e.g. lead in alloys with a lead content ≥ 85%)7(a): Lead in high melting point solders (e.g. lead in alloys with a lead content ≥ 85%) (excluding applications in Annex III, item 24)All categories (excluding applications listed in item 24 of Annex III): July 21, 2024
7(a): Lead in high melting point solders (e.g. lead in alloys with a lead content ≥ 85 %) for the following applications (excluding applications in Annex III item 24):
I) Internal interconnections between chips, or between other components and chips in semiconductor devices, with a steady-state or transient/pulsed current of 0.1 A or more or a blocking voltage of 10 V or a chip edge dimension greater than 0.3 mm x 0.3 mm
II) Integral connections (internal and external) for chip connection in electrical and electronic components, if the thermal conductivity of the solidified/sintered wafer connection material is greater than 35 W/(m*K) and the electrical conductivity of the solidified/sintered wafer connection material is greater than 4.7 MS/m and the solidus melting temperature must be above 260 °C
III) Used to make primary solder joints (internal or integral connections - both internal and external) of components for subsequent mounting of electronic components to sub-assemblies (i.e. modules or sub-circuit boards or substrates or point-to-point soldering) using secondary solder without reflowing the primary solder. Does not include die attach and hermetic sealing IV) Used to attach components to printed circuit boards or lead frames for:
   1. Solder balls used to attach ceramic ball grid arrays (BGAs)
   2. High temperature plastic overmolding (>220 °C) V) Used as a sealing material for:
   1. Ceramic packages or plugs and metal housings
   2. Component terminals and internal sub-assemblies
VI) Used to make electrical connections between lamp components in infrared heating or incandescent reflector lamps in high intensity discharge or oven lamps
VII) Audio sensors with peak operating temperatures exceeding 200 °C
All categories (excluding applications listed in item 24 of Annex III): July 21, 2026
Annex III, 7(c)-IElectrical and electronic components containing lead in glass or ceramic, other than dielectric ceramic capacitors, such as piezoelectronic devices or glass or ceramic matrix composites7(c)-I: Electrical and electronic components containing lead in glass or ceramic, other than dielectric ceramic capacitors, such as piezoelectronic devices or glass or ceramic matrix compositesAll categories: July 21, 2024
7(c)-V: Lead in glass or glass matrix compounds in electrical and electronic components having the following functions:
 1) Protection and electrical insulation of glass layers for high voltage diode beads and wafers based on lead zinc borate or lead silicon borate glass bodies*
 2) Sealants between ceramic, metal and/or glass components
 3) For connections within the process parameter window of <500 °C and a viscosity of 1013,3 dPas (i.e., the “glass transition temperature”)
4) Used as resistive materials, such as inks, with a resistivity range of 1 ohm/sq to 1 megohm/sq, excluding trimmer potentiometers**
5) For chemically modified glass surfaces in microchannel plates (MCPs), channel electron multipliers (CEMs) and resistor glass products (RGPs)
All categories: July 21, 2026
7(c)-VI: Lead in ceramics used in electrical and electronic components (excluding applications covered by 7(c)-II, 7(c)-III and 7(c)-IV) for the following functions:
1) Piezoelectric lead zirconium titanate (PZT) ceramics
2) Ceramics providing a positive temperature coefficient (PTC)
All categories: July 21, 2026
Annex III, 7(c)-IILead in dielectric ceramic capacitors of rated voltage AC 125 V or DC 250 V or higher7(c)-II: Lead in dielectric ceramic capacitors of rated voltage AC 125 V or DC 250 V or higherApplicable Product Categories:
All categories except applications covered by the exemptions in Sections 7(c)-I and 7(c)-IV of this Appendix
 July 21, 2026

According to the RoHS Directive, exemptions requested for extension remain valid during the official evaluation period. If the extension application is rejected or the exemption is revoked, a transition period of 12 to 18 months will be imposed from the date of the decision. Since exemptions are subject to removal once viable alternatives or technologies become available in the market, SGS recommends that electronic and electrical product manufacturers currently benefiting from exemptions closely monitor the latest developments regarding these exemptions and proactively prepare for supplier selection and technology upgrades to mitigate associated risks.

Sources:Pack 22 Final Report (Please refer to the original text for details)

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