Guides / Compliance

RoHS Exemption 6(c) and What Happens to Leaded Brass in 2027

September 21, 2026

If your brass part goes inside electrical or electronic equipment sold in the EU, there is a date you should have in your plan: 30 June 2027.

That is the current expiry on RoHS exemption 6(c), the clause that has allowed copper alloys containing up to 4 percent lead into electrical equipment for the whole life of the directive. Almost every leaded brass sits under it.

What 6(c) actually says

RoHS restricts lead to 0.1 percent by weight in any homogeneous material inside electrical and electronic equipment. Brass would fail that limit by a factor of thirty, so Annex III carries exemption 6(c): copper alloy containing up to 4 percent lead by weight.

That single line is why the connector shells, terminals, contact blocks and threaded inserts inside EU electronics have quietly stayed on C360 and its relatives for twenty years.

Where it stands now

The European Commission set the current expiry at 30 June 2027 in a decision published in September 2025.

A further renewal request was submitted in December 2025. Under the directive, an exemption that is the subject of a timely renewal request stays valid until the Commission decides, so the expiry date is currently suspended rather than confirmed.

Two things follow, and they point the same way.

The exemption is not gone today, so nobody has to panic.

The direction of travel over the last decade has been one way only, and each renewal has been shorter and more contested than the last. Planning on an indefinite extension is planning on a pattern that has not held.

What this is not

Three clarifications worth making, because 6(c) gets quoted at parts it does not cover.

It is not the plumbing rule. RoHS covers electrical and electronic equipment. A tap, a pipe fitting or a valve body in a water system is not EEE. Those are governed by NSF/ANSI 61 and 372 in the US and by national drinking water approvals in Europe, which are already pushing hard toward lead-free. See NSF/ANSI 61 and 372 for brass fittings.

It is not the vehicle rule. Vehicles fall under the End of Life Vehicles directive, which carries its own lead exemptions for copper alloys on a separate timetable.

It is not REACH. Lead is on the REACH candidate list as a substance of very high concern, which brings notification duties above 0.1 percent in an article. That obligation exists already and is independent of RoHS.

Who should care

Work through your parts and ask two questions about each: does it end up inside electrical or electronic equipment sold in the EU, and is it leaded brass?

Both yes, and 6(c) is what is keeping that part legal. Typical cases:

• Connector shells, contact pins and terminals
• Threaded inserts and standoffs in enclosures
• Brass parts inside appliances, meters and industrial control gear
• Cable glands and strain relief bodies

Note that it is the equipment that is regulated, not the part. A shop cannot tell you whether 6(c) applies to your part, because only you know where it ends up.

What to do in the next twelve months

Find the affected parts. You cannot plan around a list you do not have. Most buyers find fewer parts than they feared, and a few they had forgotten about.

Ask suppliers now, not in 2027. Ask the specific question: have you machined C69300 silicon brass or a bismuth brass in production, and can you supply a mill certificate for it. Most shops will say they can run it. Fewer have actually shipped it. The gap matters.

Pick the alloy per part, not per company. Bismuth brasses behave close to C360 and often run on an adapted program. Silicon brass is stronger, more corrosion resistant and further from C360 in tooling and threading terms. The right answer differs by part. See leaded and lead-free brass compared.

Budget the qualification, not just the parts. First article, customer approval, and a possible drawing revision where the new alloy changes a mechanical property. On a stronger alloy you may even be able to thin a wall, which sometimes pays for part of the change.

Watch the stress corrosion question. Bismuth brass can carry high residual stress, and brass under residual tensile stress is vulnerable to stress corrosion cracking. If the part is cold worked, or ends up near ammonia or an amine, discuss a stress relief step with the shop. See stress corrosion cracking in brass parts.

The honest summary

Nothing is illegal today. The exemption is live while a renewal is being considered.

But a supplier who has never cut lead-free brass takes months to become one who has, and that clock runs on their calendar, not yours. Buyers who start asking in 2026 will have a qualified part and a second source. Buyers who start when the decision lands will be queueing behind everyone else who waited.

This page describes the regulation as it stood in September 2026. It is not legal advice, and you should confirm the current status before making a commercial decision.

If you need shops that have actually run lead-free brass in production, send us the part and set the compliance field accordingly. We match only to shops that say yes to that question.

Frequently asked questions

Keep reading

• Leaded and Lead-Free Brass Compared, and the Standards That Decide It
• NSF/ANSI 61 and 372: What They Mean for a Brass Part