RoHS FAQ Components

Yes, when the component is used in finished EEE or as a spare part for in-scope EEE, unless a specific Article 4, Annex II, Annex III, or Annex IV provision applies. Directive 2011/65/EU requires EEE placed on the Union market, including cables and spare parts for repair, reuse, updating, or capacity upgrades, not to contain the restricted substances above the Annex II maximum concentration values in homogeneous materials.

The practical consequence is component-level evidence rather than a separate RoHS label on every part. The Commission RoHS FAQ explains that finished EEE can meet RoHS substance requirements only if its components and parts meet the substance restrictions, including non-electronic parts such as fasteners or plastic enclosures. The finished-EEE manufacturer must decide whether the supplier evidence is specific, current, and adequate for the product's technical documentation.

RoHS CE marking is tied to finished EEE. Directive 2011/65/EU requires the CE marking to be affixed visibly, legibly, and indelibly to the finished EEE or its data plate. Where that is not possible or not warranted because of the nature of the EEE, it must be affixed to the packaging and accompanying documents.

The Commission FAQ states that components used in finished EEE or for repair or upgrade of in-scope EEE must meet Article 4 substance restrictions but do not need RoHS CE marking. That substance rule is subject to the dated spare-part provisions in Article 4(4), Article 4(5), and Annex II, as well as applicable Annex III or Annex IV exemptions. Spare parts that are not finished EEE also do not need a RoHS declaration of conformity or CE mark. If an item independently meets the EEE definition and is placed on the market as a finished product for the end user, assess that item as EEE even if the supply chain calls it a component.

Start with the restricted substances and the material breakdown. 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) at 0.1%, and cadmium at 0.01%. The Commission FAQ gives practical examples of homogeneous materials such as a plastic cover, copper wire inside a cable, and the solder part of a solder joint.

Then decide whether supplier evidence is enough or whether risk-based testing is needed. EN IEC 63000:2018 is the harmonised standard listed for technical documentation assessing electrical and electronic products with respect to restricted substances; the IEC 62321 series provides test and sample-preparation methods often used when declarations need analytical support.

A component that depends on an exemption should not be treated as permanently compliant. Directive 2011/65/EU allows materials and components of EEE to be included in Annex III or IV for specific applications only when the Article 5 conditions are met, and exemption validity periods are limited and renewable.

The Commission implementation page confirms that exemption renewals must be submitted no later than 18 months before expiry and that existing exemptions with timely renewal requests remain valid until the Commission decides. Component records should therefore track the specific exemption text, application, EEE category, renewal status, and any planned substitute material or design.