Most of the exemption points in the draft are not new allowances but renewals of existing RoHS exemptions with updated wording or extended validity — so the practical question for affected manufacturers is less whether lead or cadmium may still be used, and more for how much longer.
RoHS exemption changes 2026: what's covered
The draft Delegated Directive amends Annexes III and IV of the RoHS Directive. The exemption points concerned cover medical phototherapy equipment, lighting components, optical glass, ceramic capacitors and industrial monitoring instruments that rely on lead or cadmium where no technically viable substitute exists yet.
The public feedback period on the draft closed on August 5, 2026. The Commission is now reviewing stakeholder comments before finalizing and adopting the Delegated Directive.
What the RoHS exemption changes mean for companies
RoHS exemptions are granted for limited periods and must be renewed to remain valid; if a renewal request is not granted in time, the exemption expires and use of lead or cadmium in the relevant application becomes non-compliant. Manufacturers of medical devices, lighting and industrial monitoring instruments should check whether their products rely on the specific exemption points covered by this draft.
Until the Delegated Directive is formally adopted, the current exemptions remain in force. Companies should nonetheless prepare updated declarations of conformity and communicate any change in exemption wording along the supply chain to avoid conformity gaps once the new Directive takes effect.
How IPOINT supports RoHS compliance
Keeping track of exemption points, expiry dates and substance thresholds across a product portfolio is a recurring RoHS compliance challenge. With IPOINT Compliance, companies can manage RoHS substance data and exemption status centrally and stay ready for updates like this one.
