RoHS compliance of our standard devices

On 21 November 2025, the European Commission published three Commission Delegated Directives amending Annex III of the RoHS Directive 2011/65/EU. These acts concern key lead exemptions that are also relevant for PULS standard devices:
– (EU) 2025/1802 – lead in high melting temperature solders (entry 7(a))
– (EU) 2025/2363 – lead in glass or ceramic components (entries 7(c)-I, 7(c)-II and new 7(c)-V and 7(c)-VI)
– (EU) 2025/2364 – lead as an alloying element in steel, aluminium and copper (entries 6(a), 6(b), 6(c) and their sub‑entries)

For PULS standard devices (mainly category 11 under RoHS), the following deadlines are particularly relevant:

• High melting temperature solders (7(a))
  • The general exemption 7(a) is uniformly extended until 30 June 2027.
  • In addition, several more narrowly defined sub‑exemptions 7(a)-I to 7(a)-VII are introduced; these remain valid until 31 December 2027.

• Glass/ceramic components (7(c))
  • 7(c)-I (lead in glass/ceramic in components, excluding dielectric ceramic in capacitors): valid until 30 June 2027.
  • 7(c)-II (dielectric ceramic in high‑voltage capacitors) as well as the new entries 7(c)-V (glass applications) and 7(c)-VI (ceramic applications): valid until 31 December 2027.
• Metal alloys (group 6)
  • The general entries 6(a) and 6(b) (lead in steel and aluminum) will expire after transition periods of 12 and 18 months respectively from the date the directive enters into force.
  • At the same time, the sub‑entries 6(a)-I, 6(a)-II, 6(b)-I, 6(b)-II and 6(b)-III as well as 6(c) (lead in copper alloys) are recast; for the device categories relevant to PULS they will expire no later than 30 June 2027.

Transition logic and planning certainty

• If a renewal application is submitted at least 18 months before an exemption’s expiry date, the existing exemption remains valid until the European Commission has taken its decision.

• If the renewal is rejected, a transition period of typically 12–18 months applies from the date of the decision.
• Equipment that has been lawfully placed on the market before an exemption expires may continue to be sold, distributed and used afterwards.
• For PULS, a device is generally considered to be placed on the market once it leaves our EU warehouse under a sales contract to the first customer in the European Economic Area.

What does this mean for PULS products?

• PULS ensures that only RoHS‑compliant standard devices are placed on the market.

• We are in close contact with our suppliers and obtain confirmation as to whether renewal applications have been submitted for the relevant exemptions.
• Where technically feasible and economically reasonable, we gradually reduce the use of exemptions and switch to lead‑free alternatives.
• Any material or component changes that affect our products are communicated in due time via Product Change Notifications (PCN).

Whether a specific article number makes use of a RoHS exemption is documented in the corresponding Material Declaration of Conformity (M‑DoC) in the product download area.

For further details, see also our customer information letter.