Guide
Does Free-Machining Aluminum 2011 Create a Lead Compliance Problem?
Free-machining aluminum 2011 is a copper-bearing wrought alloy that carries added lead and bismuth so it breaks into short chips on a lathe. The lead is the compliance issue: it becomes a problem only when the turned part goes into electrical or electronic equipment sold in the EU, and for that use the exemption that has allowed it ends in 2027.
By Saola Manufacturing engineering team · Published · Updated
This guide is for buyers and engineers of electronic, medical and consumer products who order small turned parts such as nuts, bushings and fittings in 2011 or 6262 and sell into Europe. It covers exactly one question: how the RoHS lead exemption for machining aluminum works, why 6262 is not the lead-free swap people assume, and what paperwork to ask for. The broader picture of RoHS and REACH for metal parts is in the RoHS and REACH guide.
This is general information about public legal texts, not legal advice. Every entry and date below is from Annex III as replaced by Commission Delegated Directive (EU) 2025/2364, checked against the Commission’s annex text, where the expiry dates are counted from the directive’s entry into force; the product category, not the part, decides which row applies. Confirm the category and dates with your compliance owner.
On this page
Does aluminum 2011 break RoHS?
Only if the part ends up in electrical or electronic equipment placed on the EU market, where lead above the general limit is banned unless an exemption covers it. A purely mechanical product is outside RoHS, although other rules such as REACH still apply.
The general rule is a maximum lead concentration of 0.1% by weight in each homogeneous material, as the Commission restates in the recitals of its 2025 amending directive (Council document 12658/25, 2025). The Aluminum Association's FAQ makes the same point for alloys: lead in aluminum is limited to 0.1%, with exemptions that allow up to 0.4% in particular cases (Aluminum Association, April 2024).
The Commission explains that lead is added to aluminum for machining purposes to improve machinability by acting as a lubricant. That is why 2011 is a RoHS question at all: it is one of the leaded machining alloys. Whether it is a problem for your part depends on the product category of the finished equipment, and on the date the equipment is placed on the market.
What does exemption 6(b)-II allow, and when does it end?
Exemption 6(b)-II allows lead up to 0.4% by weight in aluminum used for machining, and it expires on 11 June 2027 for equipment categories 1 to 7 and 10, and on 30 June 2027 for categories 9 (industrial monitoring and control) and 11. After those dates the lead must come out.
The table reproduces the aluminum rows of Annex III as replaced by Delegated Directive (EU) 2025/2364, published in the Official Journal on 21 November 2025 (EUR-Lex, 2025). Member States had to adopt the directive by 30 June 2026 and apply it from 1 July 2026, so national rules should now apply across the EU.
| Entry | What it covers | Lead limit | Expiry |
|---|---|---|---|
| 6(b) | Lead as an alloying element in aluminum, general entry | 0.4% by weight | 11 June 2027 |
| 6(b)-I | Aluminum from lead-bearing aluminum scrap recycling | 0.4% by weight | 11 December 2026 for categories 1-7 and 10; 30 June 2027 for categories 9 (industrial monitoring and control) and 11 |
| 6(b)-II | Aluminum for machining purposes | 0.4% by weight | 11 June 2027 for categories 1-7 and 10; 30 June 2027 for categories 9 (industrial monitoring and control) and 11 |
| 6(b)-III | Aluminum casting alloys from lead-bearing scrap | 0.3% by weight | 30 June 2027 for categories 1-8, 9 (other than industrial monitoring and control) and 10 |
Read the 6(b)-II row narrowly. It names categories 1 to 7, 10, and 9 and 11 for industrial instruments and open-scope equipment. It does not name category 8, medical devices, and the older general 6(b) entry that did cover categories 8, 9 and 11 also ends on 11 June 2027. Whether a particular medical or monitoring product keeps a window is a reading of the text for your product, so put that question to your compliance owner.
The entries marked with an asterisk in the directive also exclude consumer equipment that a child could put in its mouth, unless the lead release rate stays at or below 0.05 micrograms per square centimeter per hour (EUR-Lex, 2025). That matters for small turned parts in toys, wearables and other consumer products.
Do 2011 and 6262 actually fit under the exemption's lead ceiling?
Not reliably: the registered composition limits let 2011 fall either side of the exemption ceiling, and the lowest lead that 6262 allows is the ceiling itself. The only proof for a given bar is the lead figure on its mill test report.
The Aluminum Association’s registration record for wrought alloys sets lead in 2011 at 0.20 to 0.6% and bismuth at 0.20 to 0.6%, with copper at 5.0 to 6.0% (Aluminum Association, Teal Sheets, 2018). The same record sets both lead and bismuth in 6262 at 0.40 to 0.7% (Aluminum Association, 2018). These are limits, not nominal values, so any one heat can sit anywhere inside them.
Two points follow. First, a 2011 heat can be below or above the exemption’s 0.4% limit (EUR-Lex, 2025), so the exemption covers some 2011 bars and not others. Second, the minimum lead registered for 6262 equals that 0.4% limit (EUR-Lex, 2025), so almost any 6262 heat sits at or above the ceiling. Mills report the measured lead for each heat, so the report is the document that settles it.
Is 6262 the lead-free replacement for 2011?
No. 6262 contains lead as well as bismuth, so switching from 2011 to 6262 does not remove the lead problem; a lead-free bar must be ordered as such, with a lead limit in the purchase order.
The idea that 6262 swaps lead for bismuth comes from the fact that it adds bismuth. But the registered limits above require both elements in 6262. If the goal is RoHS compliance after the exemption ends, the drawing and order need a maximum lead content, for example the general RoHS limit of 0.1% by weight (Council document 12658/25, 2025), and the supplier must name the alloy that meets it.
The direction of travel is clear. The Commission's assessment found that reliable substitutes for lead in machining aluminum exist for most equipment categories, that the last application area still relying on lead was expected to move to alternatives by 2025, and that a transition of up to 18 months applies (Council document 12658/25, 2025). The aluminum industry's own FAQ reports that the European aluminum association made no renewal request for machining, suggesting that technology has closed the machinability gap (Aluminum Association, April 2024).
The same assessment found that for industrial monitoring and control instruments and open-scope equipment, moving to lead-free alloys requires redesign and, in at least some cases, requalification of the equipment, which is why those categories get the later date. Plan trial parts and a requalification step before the exemption date, not after it.
Which documents should you ask the supplier for?
Ask for the mill test report showing the measured lead, a written RoHS statement that names either the general lead limit or exemption 6(b)-II, and lot traceability from bar to part.
- The mill test report for the bar lot, with chemistry that includes lead and bismuth, so the measured lead can be compared with the exemption ceiling or the general limit of 0.1% (Council document 12658/25, 2025). See how to read a mill test report.
- A RoHS declaration that states which route the part relies on: lead at or below the general limit, or exemption 6(b)-II with its expiry date. A declaration that only says "RoHS compliant" does not tell your compliance team which one.
- The product category the declaration assumes, because the expiry differs between categories 1 to 7 and 10 and categories 9 and 11.
- A statement for each finish on the part. The limit applies to each homogeneous material separately, so a plated or conversion-coated surface is judged on its own.
- Lot traceability, so that if a heat later fails a check, the affected parts can be found.
Ask the supplier to refresh the declaration whenever the alloy, the bar source or the finish changes. The leaded alloy and the exemption are both moving targets until 2027.
How should the drawing and purchase order name the alloy?
Name the alloy, the lead limit, and the compliance route in the material note, and say whether a substitute alloy needs approval before it is used.
For a new design aimed at the EU, write the lead limit rather than a leaded alloy: material by alloy and temper, with a maximum lead content of 0.1% by weight, the general RoHS limit (Council document 12658/25, 2025). If the part is a drop-in for an existing design that relies on 2011, keep the alloy but write the exemption on the order and the date by which the design moves to a lead-free alloy.
Decide who may substitute. A supplier who swaps 2011 for 6262 to meet a stock or price need will not have removed the lead, and a swap to a lead-free alloy changes chip behavior, finish and sometimes strength. The note should say that any substitution needs written approval and a new declaration. The RFQ preparation guide lists the other fields a turned-part package needs.
Small turned parts in these alloys are covered on the CNC turning page. Send the drawing with the product category and the target market, and the quote states the alloy it is based on and which of the documents above come with the bar.
Frequently asked
Is 2011 aluminum banned in the EU?
No. RoHS restricts lead in electrical and electronic equipment, not in aluminum as a material. For that equipment the machining exemption covers leaded machining aluminum up to its 0.4% limit until its expiry date in 2027 (EUR-Lex, 2025), and outside RoHS scope the alloy is not restricted by this directive.
Does the RoHS exemption apply to parts for the US market?
RoHS is EU law, so it applies to equipment placed on the EU market. A US-only product is not covered, but many US makers export, and customers often flow the requirement down to every supplier.
Can a part machined before the expiry date still be used afterward?
The rule applies to equipment placed on the market, so the date that matters is when the finished product is placed on the EU market and not when the part was machined. Check the product plan, not the machining date.
Does a mill certificate prove RoHS compliance?
It proves the measured chemistry of the bar, including lead if the report lists it. The RoHS declaration is a separate statement that relies on that chemistry and names the route taken.
What if my product is a medical device?
Medical devices are category 8. The 6(b)-II row does not name that category, so read the directive text for your device with your compliance owner before relying on a leaded machining alloy.
Sources
- Commission Delegated Directive (EU) 2025/2364 of 8 September 2025 amending Directive 2011/65/EU as regards an exemption for lead as an alloying element in steel, aluminum and copper, Official Journal of the European Union, 21 November 2025
- Council document 12658/25, Commission cover note and draft delegated directive with explanatory memorandum, Council of the European Union, September 2025
- Aluminum Alloys: RoHS Frequently Asked Questions, The Aluminum Association, updated April 2024
- International Alloy Designations and Chemical Composition Limits for Wrought Aluminum and Wrought Aluminum Alloys (Teal Sheets), The Aluminum Association, revised August 2018
- Council document 12658/25 ADD 1, Annex to the draft Commission Delegated Directive, Council of the European Union, September 2025