RoHS applies to brass parts when they go into electrical and electronic equipment sold in the EU, such as terminals, connectors and plug pins. A plumbing fitting or a plain mechanical part is not covered by RoHS, though other rules may apply.
RoHS is the EU Restriction of Hazardous Substances Directive 2011/65/EU. It limits ten substances in each homogeneous material of electrical and electronic equipment. For lead, the limit is 0.1% by weight.
Why leaded brass can still be used
Free-machining brass contains around 3% lead, well above the 0.1% limit. It is allowed in electrical equipment under exemption 6(c) in Annex III, which covers copper alloys containing up to 4% lead by weight.
The EU reviewed the lead exemptions in 2025. Commission Delegated Directive (EU) 2025/2364, published in November 2025, kept exemption 6(c) but set it to expire on 30 June 2027. It also excludes some small consumer products that children could put in their mouths, unless lead release stays within a set limit. This is the position as of October 2026.
Exemptions can be renewed, changed or left to expire. Check the current Annex III text on EUR-Lex before you plan a product beyond 2027.
What this means for your sourcing
- If your product is electrical, record which RoHS exemption each brass part relies on.
- If the product will still be on sale after mid-2027, plan a test of low-lead or lead-free brass now.
- Ask your supplier to confirm the alloy on every lot with a mill certificate.
- Have lots tested for lead, cadmium and other restricted substances, because recycled brass can pick up contaminants.
Moving to low-lead brass
Switching alloy is not a paperwork change. Low-lead and lead-free brasses machine differently, wear tools faster and may need new cutting settings. Some also behave differently when crimped or bent.
Run a trial batch, measure it fully and test it in your assembly before you change the drawing. Allow time for any certification bodies to approve the new material, and keep the old and new parts separate during the changeover.
Other markets
The UK has its own RoHS regulations, which may not track every EU change. Several other countries have RoHS-style rules. Confirm with your test house or compliance adviser which version applies to your market.
For drinking water parts, lead limits come from water rules instead, covered in what lead-free brass is.
Who is responsible
Under RoHS, the manufacturer of the finished equipment, or the importer who places it on the EU market, is responsible for compliance. The Indian part supplier is not. You need material data and test reports from the supplier so that your technical file holds up. The guide to reading a lab certificate shows what a useful report contains.
Next step
We check documents and have lots tested for restricted substances before shipment. To plan RoHS checks for your brass parts, book a free sourcing review.