EU RoHS Directive: Technical Review of Lead-in-Solder Exemptions (7a, 7c-I, and Others) Following Transfer to ECHA
ENFORCEMENT TIMELINE
Under review, with a European Commission decision expected in 2025–2026
Overview
Among the RoHS Directive's exemptions, the two most widely relied upon by electrical, electronic, automotive, and industrial equipment manufacturers are "lead in high-melting-temperature solder" (Exemption 7a) and "lead in glass or ceramic matrix compounds" (Exemptions 7c-I and related entries).
Following the transfer of scientific evaluation to the European Chemicals Agency (ECHA), industry consortia (including JEITA and others) have submitted renewal applications, and ECHA is now developing a rigorous roadmap for narrowing, reducing, or phasing out specific use cases, based on assessments of the maturity of alternative technologies such as high-silver solder, nano-copper bonding, and transient liquid phase sintering (TLPS).
Enforcement Timeline
January 2020: Industry consortia submit renewal applications for Exemptions 7a, 7c-I, and related entries (the existing exemptions remain in effect while under review).
2024–2025: ECHA conducts additional public consultation and compiles technical evaluation advice.
Around 2026: The European Commission adopts a delegated directive formally establishing narrower use categories and expiry timelines.
Business Impact
Manufacturers of power semiconductors, automotive ECUs, and multilayer ceramic capacitors (MLCCs) need to move up implementation testing of lead-free alternative bonding technologies and long-term durability and reliability evaluation, in anticipation of a future narrowing of the scope of Exemptions 7a and 7c-I.