EU Directive 2011/65/EU (amended by 2015/863)

RoHS Compliance

When the RoHS Directive applies to brass parts in electrical & electronic equipment — and how exemption 6(c) and lead-free grades keep you compliant.

At a glance

RoHS in one screen, for brass buyers and design engineers.
Regulation
RoHS Directive 2011/65/EU (amended by (EU) 2015/863) — restricts 10 substances in EEE.
Scope
Electrical & electronic equipment only. Standalone brass plumbing, HVAC and gas fittings are not EEE.
Lead limit
0.1% in any homogeneous material — standard leaded brass (~3% Pb) exceeds this.
Exemption 6(c)
Copper alloy up to 4% lead permitted in EEE. Extended to 30 Jun 2027; further renewal under Commission review.
Lead-free route
CW724R & C11000 — compliant with no exemption needed.
From Brassland
RoHS Declaration of Conformity on request.
Background

What is RoHS?

The RoHS Directive (2011/65/EU, amended by (EU) 2015/863) restricts the use of ten hazardous substances in electrical and electronic equipment (EEE) placed on the EU market. The restricted substances are lead, mercury, cadmium, hexavalent chromium, PBB and PBDE flame retardants, and the four phthalates DEHP, BBP, DBP and DIBP. Each is capped at 0.1% by weight in any homogeneous material — except cadmium, capped at 0.01%.

Key point: RoHS applies only to EEE. A standalone brass fitting used in plumbing, HVAC or a gas system is not electrical or electronic equipment, so RoHS does not apply to it on its own.
Scope

When does RoHS apply to brass?

RoHS becomes relevant once a brass component is built into a finished EEE product — for example a brass terminal on a circuit-board assembly, a connector housing inside a consumer appliance, or a brass contact within a switchgear assembly. At that point the whole product must meet RoHS, and each material in it is assessed.

Standard CW617N brass contains roughly 3% lead, which exceeds the 0.1% limit. The RoHS Directive addresses this through Annex III exemption 6(c), which permits lead up to 4% by weight in copper alloys used in EEE, recognising that no lead-free alternative yet matches leaded brass for machinability across all applications. Lead-free grades avoid the question entirely.

By material

RoHS status by material

MaterialLead contentRoHS route (inside EEE)
CW617N — CuZn40Pb2~3% PbExemption 6(c)
CW602N — CuZn36Pb2As (DZR)~2% PbExemption 6(c)
CW724R — silicon brass<0.1% PbCompliant — no exemption
C11000 — ETP copperNoneCompliant — no exemption
The exemption

Exemption 6(c) — status & timeline

Exemption 6(c) is reviewed and renewed periodically by the European Commission. It was most recently extended to 30 June 2027. Industry submitted a further renewal application at the end of 2025, so under the RoHS Directive the exemption remains valid pending the Commission's decision — which can take additional time beyond the nominal expiry. For long-lifecycle EEE designs, it is prudent to plan a lead-free transition rather than rely indefinitely on the exemption. Always confirm the current status for your product category at the source below.

How to comply

Getting RoHS-ready brass parts

01 · CONFIRM SCOPE

Is it going into EEE?

Tell us whether the part will be built into electrical or electronic equipment — that decides whether RoHS applies at all.

02 · CHOOSE ALLOY

Exemption or lead-free

Use leaded brass under exemption 6(c), or specify CW724R / C11000 to be compliant with no exemption dependency.

03 · DOCUMENT

Declaration of Conformity

We issue a RoHS Declaration of Conformity with the material data — typically the same business day on request.

FAQ

Common questions

Are brass fittings RoHS compliant?
Standalone brass fittings used in plumbing, HVAC or gas systems are not electrical or electronic equipment (EEE), so RoHS does not apply to them. When brass is built into an EEE product, leaded grades rely on Annex III exemption 6(c) (lead up to 4% in copper alloys), while lead-free grades such as CW724R are inherently compliant.
When does RoHS exemption 6(c) expire?
Exemption 6(c) was extended by the European Commission to 30 June 2027. A further renewal application was submitted at the end of 2025, so under the RoHS Directive the exemption remains valid pending the Commission's decision, which may take additional time. For long-lifecycle EEE designs, plan a lead-free transition in advance.
Which Brassland grades are RoHS lead-free?
CW724R silicon brass and C11000 electrolytic copper contain 0.1% lead or less, so they are RoHS compliant without relying on any exemption.
Do you provide a RoHS declaration?
Yes. A RoHS Declaration of Conformity is available on request, typically the same business day. Contact us with your part details.
Sources & References

Verify against the primary source

The regulatory data summarised on this page is cross-referenced against the publishers below. Always confirm requirements against the current published text before relying on this summary.

Last reviewed: June 2026 · maintained by the Brassland compliance team. RoHS exemptions are reviewed and renewed periodically; the official EU text always prevails — verify the current expiry for your product category at the source. General guidance, not legal advice.

Need a RoHS declaration?

Declarations of Conformity, material data and test reports — typically available the same business day.