EU RoHS Directive Checklist

Directive 2011/65/EU applies to electrical and electronic equipment in the categories listed in Annex I, subject to the Directive's exclusions. The definition covers equipment dependent on electric currents or electromagnetic fields for at least one intended function and designed for voltage ratings not exceeding 1,000 volts AC or 1,500 volts DC.

Do not treat every assembly, cable, spare part, component, or building installation the same way. The checklist should record whether the item is finished EEE, a separately placed cable, a spare part, a component for integration, or equipment claimed to be outside scope under a specific exclusion.

Article 2 excludes equipment necessary for security or military purposes, equipment designed to be sent into space, qualifying means of transport, large-scale stationary industrial tools, large-scale fixed installations, certain non-road mobile machinery, active implantable medical devices, qualifying photovoltaic panels, and custom-built business-to-business research equipment. The large-scale exclusions require the full installation or tool definition; ordinary large products, stand-alone machines, or equipment merely used in a building do not qualify on size or location alone.

RoHS substance limits are assessed by weight in each homogeneous material, not by the weight of the complete product. A homogeneous material is a material of uniform composition throughout, or a material combination that cannot be separated into different materials by mechanical actions such as unscrewing, cutting, crushing, grinding, or abrasive processes.

The current Annex II list includes lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB), polybrominated diphenyl ethers (PBDE), bis(2-ethylhexyl) phthalate (DEHP), butyl benzyl phthalate (BBP), dibutyl phthalate (DBP), and diisobutyl phthalate (DIBP). Cadmium has a maximum concentration value of 0.01 % by weight in homogeneous materials; the other listed substances have 0.1 % values unless an applicable exemption changes the conclusion for the specific use.

Manufacturers must draw up the required technical documentation, complete the conformity assessment procedure, draw up an EU declaration of conformity, and affix CE marking when compliance has been demonstrated. Directive 2011/65/EU also requires manufacturers to keep the technical documentation and EU declaration of conformity for 10 years after the EEE has been placed on the market.

EN IEC 63000:2018 is the harmonised standard referenced for technical documentation used to assess materials, components, and EEE against RoHS substance restrictions. The checklist should identify which evidence supports the declaration rather than treating a supplier statement as a substitute for the manufacturer's file.

Annex III and Annex IV exemptions are application-specific and limited in time. A checklist should identify the exact exemption entry, product category, material or component use, expiry conditions, and evidence showing that the product fits the exemption wording.

Commission implementation guidance states that renewal applications must be made no later than 18 months before an exemption expires. Existing exemptions with timely renewal requests remain valid until the Commission decides, while a new exemption request does not itself allow non-compliant equipment to be placed on the EU market before the exemption is granted.

The Directive permits exemption validity of up to five years for Annex I categories 1 to 7, 10, and 11 and up to seven years for categories 8 and 9, but the adopted entry controls the actual period. After rejection or revocation, the legal expiry falls 12 to 18 months after the decision. Use the current consolidated Annex and adopted act, not an assessment report or supplier estimate, for the release date.