The European Commission published a draft Delegated Directive proposing renewed and updated time-limited RoHS Annex III/IV exemptions for lead and cadmium in specified electrical and electronic equipment (EEE), and opened a public feedback period running to August 5, 2026.
What Happened
On July 8, 2026, the Commission published the draft Delegated Directive amending Annexes III and IV of the RoHS Directive (2011/65/EU), updating exemption points for lead and cadmium in EEE to reflect scientific and technical progress. The draft covers renewals for uses such as cadmium in helium-cadmium lasers (Raman spectrometers and general applications) and lead in superconducting circuits/thermal conductors for MRI and NMR equipment.
What’s New
- Renewal/update of time-limited Annex III (general EEE) and Annex IV (medical devices, monitoring & control instruments) exemptions for lead and cadmium.
- Cadmium in helium-cadmium lasers: 30-month extension for specific applications (e.g., Raman spectrometers); 12-month expiry for general uses.
- Lead in superconducting circuits and thermal conductors (MRI/NMR): explicit 12-month expiry dates from date of entry into force.
Key Dates & Compliance Deadlines
Commission published the draft Delegated Directive for public feedback.
Public feedback period closes.
Adoption and entry-into-force dates to follow Commission review of feedback.
Affected Industries
Electronics and electrical equipment manufacturers; medical device manufacturers; industrial monitoring and control instrument producers; laser and spectroscopy equipment makers; EU supply chains.
Who Is Affected
EEE manufacturers and importers relying on the affected lead/cadmium exemptions, particularly medical imaging (MRI/NMR) and laser/spectrometer equipment producers.
Substances / Products in Scope
Lead and cadmium, restricted substances under RoHS Annex II; exemptions under Annex III (general EEE) and Annex IV (medical devices/monitoring & control instruments).
Prohibitions, Restrictions & Exemptions
No new restrictions — this is a renewal and technical update of existing time-limited exemptions. Failure to secure renewal before expiry would mean the underlying RoHS lead/cadmium restriction applies without exemption.
What Companies Should Do
- Submit feedback on the draft Delegated Directive before the August 5, 2026 deadline if affected.
- Audit bills of materials for lead- or cadmium-dependent components covered by the affected exemption entries.
- Track final adoption and transposition timelines to avoid using an exemption past its (renewed or expired) date.
This is a routine but consequential technical maintenance update to RoHS exemptions; medical device and laser/instrumentation manufacturers relying on the specific lead/cadmium exemption entries should confirm renewal status before the current entries lapse.
Reference: https://www.productcomplianceinstitute.com/2026/07/16/eu-updates-to-eu-rohs-as-regards-exemption-points-for-lead-and-cadmium-in-certain-electrical-and-electronic-equipment/ | https://chemical.chemlinked.com/news/chemical-news/european-commission-proposes-updates-to-rohs-exemptions-for-lead-and-cadmium-in-eee
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