Lead in Electronics 2026: What Changes for EEE Manufacturers

Key data

Manufacturers of electrical and electronic equipment that depend on lead in certain production processes have three more years of leeway: Order PJC/904/2026, published on August 29, 2026, expands and reorganizes exemptions for the use of lead under the RoHS directive. The regulation transposes three EU delegated directives of 2025 and modifies points 6 and 7 of Annex III of Royal Decree 219/2013.

The key for compliance and operations teams: the exemption is not generic. It is divided into specific subcategories, which requires reviewing which one each company application fits into.

What does this regulation establish?

Order PJC/904/2026 modifies Annex III of RD 219/2013, which regulates exemptions for the use of hazardous substances in EEE (RoHS directive). The changes affect two specific points:

Point 6 — High-melting-point solder pastes

Solders with more than 85% lead maintain the exemption, but are reorganized into seven subcategories. The reason: there are no reliable technical alternatives for all applications in the next three years. The division into subcategories allows for more specific evaluations per application in future technical reviews, rather than reviewing the exemption globally.

Point 7 — Lead in glass, ceramics and metal alloys

Comparison: before and after

Economic and operational impact

The direct impact for most manufacturers is neutral in the short term: the regulation does not prohibit anything that was previously allowed nor does it add new fees or penalties. However, there are two operational effects that must be managed:

• Mandatory reclassification: Companies that previously relied on the generic exemption in point 6 must now identify which of the 7 subcategories their processes fit into. Without this reclassification, regulatory compliance is questionable in the event of an inspection.
• 0.3% limit on recycled aluminum: Companies using recycled aluminum with lead as an alloying element must verify that their suppliers comply with this threshold. If lead content exceeds 0.3% by weight, the material is no longer exempt and its use in EEE could constitute a RoHS violation.
• Three-year horizon: The exemption is maintained because there are no reliable technical alternatives today. But the three-year timeframe indicates that the EU expects alternatives to mature. Companies with greater dependence on lead in solders should already begin evaluating substitute technologies.

Who does it affect?

• Manufacturers of industrial and automotive electronic equipment using solders with more than 85% lead
• Manufacturers of glass or ceramic components for EEE (capacitors, resistors, sensors)
• Companies incorporating recycled aluminum as an alloying material in EEE components
• Manufacturers of EEE using steel or copper with lead as an alloying element
• Distributors of EEE who must guarantee RoHS compliance of the products they market
• Regulatory compliance officers and R&D teams of companies in the electronics sector

Practical example

A manufacturer of power modules for industrial electronics uses solder pastes with 90% lead in its high-temperature assembly processes. Until now, its RoHS exemption was based on the generic entry in point 6 of Annex III of RD 219/2013.

With Order PJC/904/2026, that manufacturer must:

1. Identify which of the 7 new subcategories in point 6 its specific application fits into (for example, power modules for electric traction or high-reliability equipment).
2. Update its technical documentation and RoHS declaration of conformity to reflect the specific subcategory, not the previous generic entry.
3. If it also uses recycled aluminum in housings or heat sinks, verify with its suppliers that lead content does not exceed 0.3% by weight.

Without these steps, in the event of an audit or market inspection, the company may not properly demonstrate its exemption, even though it technically continues to meet the material requirements.

What should companies do now?

1. Audit lead use in production processes: Identify which applications use solders with more than 85% lead and which subcategory of the new point 6 each one corresponds to.
2. Verify lead content in recycled aluminum: Request from suppliers the technical sheet or composition certificate proving that lead does not exceed 0.3% by weight in the aluminum alloys used in EEE.
3. Update RoHS compliance documentation: Review declarations of conformity, technical sheets and technical files to reflect the specific subcategories of the new Annex III, not the previous generic entries.
4. Review glass and ceramic components: Check whether affected components are still covered by the new separate entries in point 7 and update regulatory references in the documentation.
5. Plan technological transition: Given that the exemption period is approximately three years, begin evaluating lead-free alternatives for the most critical applications, especially in high-melting-point solders.

Official source

Consult complete regulation in official source

Notice: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-18281