EU RoHS Directive (2011/65/EU) Applicability Test

RoHS applies to electrical and electronic equipment (EEE) placed on the EU market. Start with product facts, not internal labels.

If your product includes embedded electronics, treat it as a candidate for RoHS unless an exclusion clearly applies.

Category mapping matters because Article 4 staged dates, exemption validity periods, and spare-parts rules can differ by category.

Before you conclude that a product is in scope, run the Article 2(4) exclusions check and document the evidence for any exclusion you rely on.

RoHS scope often expands through what you ship with the product: cables, adapters, assemblies, and spare parts.

Decide whether the cable or spare part is finished EEE, whether it is placed on the market as a stand-alone item, and whether the repair or reuse carve-outs apply.

Scope is only useful if it triggers a concrete work plan.

Once in scope, RoHS becomes a portfolio program: restricted substances controls + supplier evidence + exemptions tracking + technical documentation.

Write a 5 - 10 line scope memo and store it with your technical documentation.

If variants differ, list them explicitly (variant A in scope, variant B out of scope, etc.).