RoHS Exemption 6(c) — the rule that lets leaded brass (up to 4 % Pb) be sold into EU electrical and electronic equipment — expires on 30 June 2027. After that date, products containing CW617N, CW614N and other leaded brass alloys cannot be placed on the EU market in EEE applications without a renewed exemption. If your product will still be placed on the EU market after that date, you need to plan the lead-free transition now. This article maps every option, with cost and performance trade-offs.
For nearly two decades, European brass-fitting customers have relied on RoHS Exemption 6(c) to continue using leaded brass in electrical and electronic equipment. The exemption, which permits copper alloys containing up to 4% lead by weight, has been renewed multiple times since 2003. The latest renewal was adopted in September 2025 and published as Commission Delegated Directive (EU) 2025/2364 (OJ 21 November 2025), extending validity to 30 June 2027. That deadline is now firmly in sight — and any new product platform with a five-year lifecycle is already in the danger zone.
The European Commission has signalled that further renewals are not guaranteed. Engineering teams designing new EEE platforms today need to either qualify lead-free brass alternatives or, where leaded brass is structurally necessary, rely on a renewal request having been filed in time — requests had to reach the Commission 18 months before expiry, i.e. by 31 December 2025. This article maps the practical decision space.
What Exemption 6(c) actually allows
The exemption permits copper alloys with up to 4% lead by weight to be used as a homogeneous material in any electrical or electronic equipment that falls under the scope of RoHS 2 (Directive 2011/65/EU as amended). Entry 6(c) of Annex III reads:
"Copper alloy containing up to 4 % lead by weight."
This single line is the reason CW617N (Pb 1.6–2.2%) and CW614N (Pb 2.2–3.5%) have continued to dominate brass-fitting production for the European market. Without this exemption, every leaded brass fitting in every EEE product would already be non-compliant.
The 30 June 2027 deadline — what happens next
On 1 July 2027, unless Exemption 6(c) is renewed, the general RoHS limit of 0.1% lead by weight in homogeneous materials applies to copper alloys. That limit excludes essentially all standard leaded brass grades:
| Alloy | Typical Pb (%) | Post-2027 status (without renewal) |
|---|---|---|
| CW617N (CuZn40Pb2) | 1.6–2.2 | Non-compliant in EEE |
| CW614N (CuZn39Pb3) | 2.2–3.5 | Non-compliant in EEE |
| CW625N (CuZn35Pb1.5AlAs) | 1.2–1.6 | Non-compliant in EEE |
| CW602N (CuZn36Pb2As, DZR) | 1.7–2.8 | Non-compliant in EEE |
| CW607N (CuZn38Pb1) | 0.8–1.6 | Non-compliant in EEE |
| CW724R (CuZn21Si3P, silicon) | ≤ 0.10 | ✓ Compliant (no exemption required) |
| C6802 (bismuth brass) | ≤ 0.10 | ✓ Compliant (no exemption required) |
| CuZn37 (CW508L) | ≤ 0.10 | ✓ Compliant |
| CW510L (CuZn42) | ≤ 0.2 | Compliant only if the heat is ≤ 0.10 — specify it |
| C11000 (Cu-ETP, pure copper) | ≤ 0.005 | ✓ Compliant |
The four practical options for engineering teams
Option 1: Switch to lead-free brass — CW724R (silicon) or C6802 (bismuth)
For most plumbing, electrical, and automotive brass fittings the cleanest answer is to qualify a lead-free silicon brass. CW724R (CuZn21Si3P) is the European reference; C6802 (bismuth brass, JIS H3250) is a Japanese (JIS) grade that is also used for North American programmes and in products certified to NSF/ANSI 61 for drinking water.
Properties to expect when switching from CW617N:
- Machinability is about 85% for CW724R against the free-cutting benchmark (CW614N = 100%); C6802 is classed as a free-cutting brass in JIS H3250. Cycle times are longer than with leaded brass; how much depends on grade and geometry.
- Strength is higher (Rm ≥ 600 MPa for CW724R R600 vs ≥ 360 MPa for CW617N R360).
- Dezincification resistance is intrinsic (no arsenic addition needed).
- Cost per kg is higher than for leaded brass; ask for a comparative quotation on your own part.
- Drinking-water approvals — CW724R is on the European positive list of metallic compositions (Decision (EU) 2024/367); C6802 is used in NSF/ANSI 61 certified products. In every scheme the approval belongs to the finished product, not to the alloy.
Option 2: Switch to alpha-brass for cosmetic / non-pressure parts
For brass parts that don't see pressure — door hardware, cosmetic fittings, name plates — alpha brass CuZn37 (CW508L) is the lowest-cost lead-free option. Machinability is about 35% of CW614N, so cycle times run considerably longer, but the alloy has excellent cold-formability and no lead added (Pb ≤0.10%).
Option 3: Switch to pure copper for electrical-conductivity parts
For terminals, busbars, contact pieces and grounding components where electrical conductivity is the primary driver, C11000 (Cu-ETP) is the natural answer. 100% IACS conductivity, lead ≤0.005%, no exemption required. Machinability drops to ~20%, which makes cost per part higher, but for high-current parts the conductivity gain is worth it.
Option 4: Renewal application for Exemption 6(c)
For specific applications where lead-free alternatives genuinely cannot meet the technical requirement (very high cycle counts, ultra-fine machined features, niche metallurgical needs), industry can request a renewal from the European Commission. Requests have to be filed at least 18 months before an exemption expires — for 6(c) that date was 31 December 2025 — and, where a valid request was filed in time, the exemption remains in force until the Commission decides on it. A request needs technical evidence that lead-free alternatives are not yet feasible, and a renewed exemption is time-limited. Check the Commission's RoHS pages for the current status before you rely on it.
A practical 18-month transition plan
| Month | Action |
|---|---|
| 0–3 | Inventory of every brass-containing part across the product range; classify as EEE-scope or not; flag Pb > 0.1% parts |
| 3–6 | Engineering review of each flagged part — propose lead-free alloy substitution (CW724R, C6802, CuZn37, C11000) |
| 6–9 | Prototype + first article inspection on new alloy; performance testing (pressure, life, conductivity as applicable) |
| 9–12 | Supplier qualification of lead-free brass parts; update mill certificates; revised PPAP / FAI documents |
| 12–18 | Phased production switchover; inventory burn-down of leaded stock; documentation update (DoC, technical file) |
Cost implications for procurement
Moving a part from CW617N or CW614N to CW724R raises its price, for four reasons:
- Material cost — silicon brass costs more per kilogram than leaded brass
- Cycle time — machinability is about 85 against 100, so cycles are longer
- Tool life — the alloy is harder and wears tools faster
- Recovery — swarf has to be kept as a separate scrap stream
How much depends on how the part cost splits between material and machining time, so there is no honest universal percentage — ask for a comparative quotation on your own drawing in both alloys.
Markets already requiring lead-free brass (regardless of RoHS)
Several major markets already restrict lead in brass for drinking-water contact, independent of RoHS:
- USA — since 4 January 2014, Section 1417 of the Safe Drinking Water Act limits lead to a weighted average of 0.25% across wetted surfaces (verified to NSF/ANSI 372); California introduced the same limit first with AB 1953
- Canada — the plumbing codes and product standards reference the same 0.25% weighted-average limit
- EU — the European positive list for metallic materials (Decision (EU) 2024/367, applying from 31 December 2026) contains no leaded brass; compositions approved nationally before that date may be used until 31 December 2032, and the lead value for drinking water falls from 10 to 5 µg/L in January 2036
- Germany — until the European list applies, the UBA evaluation criteria for metallic materials (binding under the Trinkwasserverordnung) are the national rule and list the accepted alloys by product group
For OEMs exporting to multiple markets, qualifying CW724R now solves both the 2027 RoHS deadline and the drinking-water requirements above in one step. C6802 covers RoHS and the US lead limit; it is not on the European positive list for drinking water.
Sources & references
- RoHS 2 Directive 2011/65/EU (consolidated text on EUR-Lex)
- Oeko-Institut RoHS exemption review platform — evaluation archive of RoHS exemption requests
- Copper Development Association RoHS FAQ for copper & brass alloys (PDF)
- European Copper Institute
- Brassland RoHS compliance page
Frequently asked questions
What is the RoHS 2027 deadline for brass?
Which lead-free brass grades should I move to?
What should buyers do now about lead-free brass?
Sources & references
Regulatory references:
Last reviewed: September 2026. Standards and regulatory references are checked at each review.