EU RoHS Directive FAQ

RoHS applies to electrical and electronic equipment that falls within the categories in Annex I unless a specific Article 2 exclusion applies. The Directive defines EEE as equipment dependent on electric currents or electromagnetic fields to work properly, including equipment for generating, transferring, or measuring those currents or fields, within the stated voltage ratings.

A scope answer should not stop at a product label. Record the intended function, electrical dependency, Annex I category, whether the product is finished EEE or a component, and whether any exclusion such as large-scale stationary industrial tools or large-scale fixed installations is being relied on.

Commission guidance gives a gas cooker with an electrical clock, a singing teddy bear, lighted sports shoes, and petrol equipment with electric ignition as indicative EEE examples because an intended function depends on electricity. It treats independently usable, separable wardrobe lighting as EEE while the furniture can remain outside scope. The FAQ is non-binding guidance; the Directive and the actual marketed configuration control the result.

Annex II sets maximum concentration values by weight in homogeneous materials. Lead, mercury, 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) are listed at 0.1%; cadmium is listed at 0.01%. These limits apply at homogeneous-material level, not as an average across the finished product.

The consolidated Directive defines a homogeneous material as a material of uniform composition or a material combination that cannot be separated into different materials by mechanical actions such as unscrewing, cutting, crushing, grinding, or abrasive processes.

Cables, spare parts, and components are frequent sources of RoHS mistakes because the substance restrictions and CE-marking duties are not always identical. Article 4 covers EEE placed on the market, including cables and spare parts for repair, reuse, updating, or capacity upgrading, but the FAQ guidance distinguishes finished EEE from internal wiring, external cables, and components supplied for integration.

Internal wires and components used in finished EEE need substance evidence because the finished EEE can comply only if its parts meet the relevant material restrictions. They generally do not need their own RoHS CE marking or EU declaration of conformity unless they are themselves finished EEE placed on the market.

Manufacturers must draw up the required technical documentation, carry out or have carried out the applicable internal production control procedure, draw up an EU declaration of conformity when compliance has been demonstrated, affix the CE marking, and keep the technical documentation and declaration for 10 years after the EEE has been placed on the market.

EN IEC 63000:2018 is the harmonised standard reference published for technical documentation used to assess materials, components, and EEE under RoHS. Using the harmonised standard supports presumption of conformity for the requirements covered by that standard, but it does not remove the need for product-specific evidence or corrective action when non-conformity is found.

RoHS exemptions are not blanket product approvals. The Commission guidance and Directive framework treat exemptions as time-limited, application-specific entries that must be read against the exact substance, material or component, EEE category, application wording, and expiry or review status.

An exemption decision should record whether the exemption is already listed in Annex III or IV, whether it applies to the relevant EEE category, whether the application wording fits the actual use, and what review trigger will reopen the decision before expiry, supplier change, redesign, or authority challenge.