Spain updates lead exemptions in electronic devices

The Ministry of the Presidency, Justice and Relations with the Courts has published Order PJC/904/2026, of August 26, which modifies Annex III of Royal Decree 219/2013, of March 22, regarding restrictions on the use of certain hazardous substances in electrical and electronic equipment. The regulation, published in the Official State Gazette number 213 on Saturday, August 29, 2026 (reference BOE-A-2026-18281), enters into force on the day following its publication.

The order transposes into Spanish law three delegated directives from the European Commission, all dated September 8, 2025, which adapt Directive 2011/65/EU (known as the RoHS directive) to scientific and technical progress. These are Delegated Directive (EU) 2025/1802 (lead in high melting temperature solder pastes), (EU) 2025/2363 (lead in glass or ceramics), and (EU) 2025/2364 (lead as an alloying element in steel, aluminum, and copper).

Renewed and reorganized exemptions

The order reforms points 6 and 7 of Annex III, which list the applications exempt from the lead restriction. The Commission’s assessment concluded that, in several uses, lead remains technically irreplaceable or substitutes are not sufficiently reliable; therefore, the exemptions are extended with staggered deadlines:

Steel for machining and galvanizing: up to 0.35% by weight, expiring on December 11, 2026, or June 30, 2027, depending on the section.
Aluminum alloy: up to 0.4% by weight; a new section 6.b).4. is added for casting alloys from recycled scrap, with a limit of 0.3%.
Copper: alloys with up to 4% lead, expiring on June 30, 2027.
High melting temperature solder pastes (with 85% or more lead by weight), divided into eight sub-entries according to their application.

Child protection

The exemptions for steel, aluminum, and copper incorporate a child protection clause: they do not apply to electrical and electronic equipment (EEE) intended for the general public when children may place them in their mouths. The exemption is only maintained if it is demonstrated that the lead release rate does not exceed 0.05 μg/cm² per hour and that the coating guarantees this limit for at least two years of normal use. An EEE is considered capable of being placed in the mouth if it measures less than 5 cm in any of its dimensions.

Glass and ceramics

The exemption in point 7.c).1.º is divided into two new entries to allow for a more specific assessment: 7.c).5.º for lead in glass (high-voltage diode beads, hermetic sealing, resistive inks, or microchannel plates) and 7.c).6.º for lead in ceramics (piezoelectric with lead zirconate titanate or with a positive temperature coefficient). The Commission found that the substitution of lead in these materials is technically impossible in most applications or that lead-free capacitors lack sufficient reliability.

The order, signed by Minister Félix Bolaños García at the proposal of the heads of Ecological Transition and the Demographic Challenge, Industry and Tourism, and Health, and with a report from the Council of State, has the character of basic regulation and does not introduce new administrative burdens. For manufacturers of electrical and electronic equipment, the regulation sets a clear expiration schedule for the exemptions—with milestones in December 2026 and June and December 2027—which necessitates planning the substitution of lead in solders, glasses, and alloys in the coming months.

Source: Official State Gazette, no. 213, Saturday, August 29, 2026, Sec. I, page 117153 (official reference: BOE-A-2026-18281).