RoHS hasn’t come up much in our recent posts, but there are three separate exemption developments worth tracking together right now, plus one deadline that isn’t a draft at all: it’s already fixed on the calendar.
Pack 29: thirteen exemption requests under assessment
A stakeholder consultation on thirteen exemption requests closed on 1 August 2026. It covers ten Annex III renewals relating to mercury in special-purpose gas discharge lamps, plus Annex IV revocation requests covering lead and cadmium in ionising radiation detectors, ion-selective electrodes and radiation amplification devices. Assessment is under way, but there’s no draft act yet, so nothing here is decided.
A separate draft delegated directive
A different, separate draft delegated directive covers 14 Annex III and 6 Annex IV exemptions, including lead in optical glasses and ceramics, cadmium in laser systems and oxygen sensors, and lead in medical device components. Its consultation closed 5 August 2026. The draft’s expiry periods are still placeholders at this stage, and it hasn’t been adopted or published. Worth watching, not worth acting on yet.
The deadline that’s already fixed
Unlike the two items above, this one isn’t a draft: exemption 6(a), covering lead as an alloying element in steel, expires for categories 8, 9 and 11 on 11 December 2026. In RoHS terms, that’s medical devices (category 8), monitoring and control instruments including industrial monitoring and control instruments (category 9), and other electrical and electronic equipment not covered elsewhere (category 11). If you rely on this exemption for steel components in any of those three categories, the expiry date is real and it’s close.
What to do now
- If exemption 6(a) applies to steel components you place on the market in categories 8, 9 or 11, treat 11 December 2026 as a hard deadline and start planning for it now, not in November.
- Check whether any of your products are affected by the Pack 29 exemption requests or the separate draft delegated directive, and note them as a watching brief rather than something requiring immediate action.
- Keep the three items separate in your own tracking. They’re moving on different timelines, and treating them as one bundled update risks missing the one with an actual fixed date.
How we can help
We help clients track RoHS exemption timelines properly, separating what’s genuinely fixed from what’s still in draft, and plan substitution or renewal applications with enough lead time to actually meet a hard deadline like this one. Get in touch if exemption 6(a) affects your product range and you need a plan before December.
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