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FAQEU

RoHS FAQ EEE scope under EU RoHS

Under Directive 2011/65/EU, RoHS applies to in Annex I unless an Article 2 exclusion applies. The first test is whether the product needs electric currents or electromagnetic fields for at least one intended function.

This page helps separate finished , components, cables, consumables, spare parts, professional equipment, and excluded equipment before building the RoHS evidence file.

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Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
4 sections4 primary sources
Overview

EU RoHS scope starts with the Directive's definition: equipment is EEE when it is dependent on electric currents or electromagnetic fields to work properly, including when electricity is needed for only one intended function. If the product is EEE, map it to an Annex I category, check the Article 2 exclusions, and then decide whether the substance restrictions, technical documentation, EU declaration of conformity, and CE marking duties apply.

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4 of 4 questions
Question 1

Which electrical and electronic equipment is in scope under EU RoHS?

A product is in RoHS scope when it meets the Directive's definition of electrical and electronic equipment, falls within one of the Annex I categories, and is not covered by an Article 2(4) exclusion. The manufacturer, importer, and distributor duties then attach to placing or making that available on the Union market.

The definition is broader than products whose main purpose is electrical. The Commission FAQ explains that a product can be where an electric function is only a minor but intended and integral function, such as a gas cooker with an electrical clock or petrol-powered equipment with an electric spark for ignition.

Do not stop at a broad product label. A finished product, a separately marketed cable, a component sold as a finished product, or a consumable with an EEE constituent can each need its own RoHS scope analysis.

  • Start with Article 3: does the product need electric currents or electromagnetic fields for at least one intended function, or generate, transfer, or measure them?
  • Confirm the voltage design limit in the definition: not exceeding 1,000 V AC or 1,500 V DC.
  • Assign the product to one of the 11 Annex I categories, including category 11 for other not covered by categories 1 to 10.
  • Check Article 2(4) exclusions, including , , means of transport except non-type-approved electric two-wheel vehicles, active implantable medical devices, certain photovoltaic panels, business-to-business R&D-only equipment, and pipe organs.
  • For the Article 2(4)(c) exclusion, the equipment must be specifically designed and installed as part of another excluded or out-of-scope type of equipment, must fulfil its function only as part of that equipment, and must be replaceable only by the same specifically designed equipment.
  • If a product has both excluded and in-scope uses, Commission guidance says it must comply for the in-scope use; an exclusion rationale needs product-specific design and intended-use evidence.

Which electrical and electronic equipment is in scope under EU RoHS?

is generally in scope when it needs electric currents or electromagnetic fields for at least one intended function, fits an Annex I EEE category, and is not excluded by Article 2(4). The analysis should cover the finished product, separately marketed cables, EEE consumables, and components sold as finished EEE products. Components used inside in-scope EEE must meet the substance restrictions even when they do not need their own CE marking.

What evidence should support an EU RoHS scope decision?

Keep the product description, intended functions, voltage rating, Annex I category, Article 2(4) exclusion analysis, component and cable treatment, intended-use evidence, supplier material declarations, test or assessment records where used, and the owner who approved the conclusion. If an exclusion depends on specific design or use, keep sales documents, installation instructions, marketing materials, or customer-use restrictions that support that conclusion.

Question 2

Scope questions that usually change the answer

RoHS scope often turns on how the product is placed on the market, not only on what it contains. The same physical item may be assessed differently if it is sold as a finished product, built into another EEE, sold only as a component for integration, or designed solely for an excluded application.

The Commission FAQ also draws a distinction between electrical parts that are integrated into the product's intended function and detachable that can be separated and used as a fully functional product. That distinction matters for furniture with lighting, cards and boards, consumables, RFID tags, and similar mixed products.

  • Finished : if placed on the EU market for direct use by an end user and it meets the EEE definition, assess it under RoHS.
  • Components and parts: parts used in finished in-scope must meet Article 4 substance restrictions, including non-electrical parts such as fasteners or plastic cases, but components do not automatically need separate CE marking.
  • Cables: cables are generally in RoHS scope unless they belong to or a combination of EEE outside scope; external cables placed on the market separately need their own scope and conformity treatment.
  • Consumables: consumables are in scope only where they include an equipment constituent that meets the definition, such as the Commission FAQ's printer-cartridge example.
  • Professional or industrial use: RoHS does not generally distinguish consumer from professional , although specific Article 2 exclusions or timing rules may apply.
  • Multiple use: with at least one intended in-scope use must comply; excluded-use evidence needs to show the product is made available only for the excluded use.
Question 3

Evidence to keep for the EEE scope file

A useful RoHS scope file should let product, quality, procurement, and legal reviewers see why the product is in scope, out of scope, or escalated for interpretation. It should also connect the scope answer to downstream RoHS work: restricted-substance assessment, technical documentation, EU declaration of conformity, CE marking, exemptions, and change control.

If the conclusion relies on an exclusion, keep the facts that prove every condition of that exclusion. For large-scale tools and installations, that means documenting permanence, professional installation and de-installation, intended location, industrial or dedicated use, and the size or complexity indicators used. For specifically designed equipment, keep evidence that it can fulfil its function only as part of excluded or out-of-scope equipment.

  • Product identity: model, stock-keeping unit (SKU), configuration, voltage rating, photographs or diagrams, and the function that depends on electricity or electromagnetic fields.
  • Market facts: who places it on the EU market, whether it is finished , a component, a cable, a spare part, a consumable, or equipment supplied only for integration.
  • Category and exclusion mapping: Annex I category, Article 2(4) exclusion considered, and a short reason for accepting or rejecting each relevant exclusion.
  • Material compliance link: bill of materials (BOM), material declarations, restricted-substance matrix, supplier declarations, test or screening records where used, and exemption references where a restricted substance is intentionally relied on.
  • Conformity records: technical documentation, EU declaration of conformity fields, CE marking basis, change-control history, and records kept for the 10-year manufacturer retention period after placing on the market.
  • Review triggers: new supplier, material or component change, changed intended use, new sales channel, new market placement facts, changed harmonised standard or technical specification, exemption change, or authority request.
Recommended next step

Record and approve the RoHS scope conclusion

Use the EEE definition, Annex I category, Article 2 exclusion analysis, and product evidence to decide whether the item needs RoHS substance controls, technical documentation, an EU declaration of conformity, and CE marking.

Research workflow
Open Research Copilot

Answer RoHS scope, timing, and interpretation questions with cited outputs.

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Talk through implementation

Review your scope, evidence model, controls, and next actions.

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Question 4

Common EEE scope mistakes

Most weak RoHS scope records either assume that a product family label answers the legal question, or they cite an exclusion without proving the specific conditions. The scope answer should be a product-specific conclusion tied to the version placed on the EU market.

Avoid treating RoHS as only a finished-product label check. Scope and substance compliance need to be maintained through design, procurement, supplier changes, repair parts, and market-facing documentation.

  • Do not treat professional or industrial use as an automatic exclusion; RoHS still applies unless a specific exclusion or timing rule fits.
  • Do not assume equipment installed in a building is out of scope merely because it is in a building; the Commission FAQ says buildings are not equipment for the Article 2(4)(c) exclusion.
  • Do not use a large-scale fixed installation or large-scale stationary industrial tool exclusion unless the file shows all required criteria, not just size or weight.
  • Do not ignore non-electrical components of in-scope ; Article 4 applies at homogeneous-material level across the equipment.
  • Do not rely on an old supplier declaration after intended use, component, material, supplier, category, exemption, or market-placement facts change.
Primary sources

References and citations

Directive 2011/65/EU on restriction of hazardous substances (RoHS)
eur-lex.europa.eu5 citations
Referenced sections
  • Primary legal source for the RoHS scope test, EEE definition, Annex I categories, Article 2 exclusions, restricted-substance rule, and manufacturer documentation duties.
  • Primary legal source for the EEE definition, Annex I categories, Article 2 exclusions, Article 4 restriction rule, and manufacturer documentation duties.
  • Primary legal source for cables, spare parts, homogeneous-material restrictions, economic-operator roles, and the Annex I EEE categories.
Show 2 more
  • Primary legal source for Article 7 manufacturer obligations, the 10-year technical-documentation and declaration retention rule, and Annex VI declaration fields.
  • Primary legal source for homogeneous-material restrictions, exclusions, and manufacturer change-control duties.
"This Directive shall, subject to paragraph 2, apply to EEE falling within the categories set out in Annex I."
More quoted passages
"dependent on electric currents or electromagnetic fields"
"including cables and spare parts"
"keep the technical documentation and the EU declaration of conformity for 10 years"
"Changes in product design or characteristics"
European Commission RoHS 2 FAQ key guidance document
environment.ec.europa.eu5 citations
Referenced sections
  • Commission FAQ guidance used for practical scope examples covering intended electrical functions, exclusions, large-scale equipment, cables, components, consumables, and multiple-use EEE.
  • Commission FAQ guidance used for practical scope examples on intended electrical functions, multiple-use products, components, cables, consumables, and large-scale exclusions.
  • Commission FAQ guidance supporting the practical treatment of finished products, components, consumables, cables, professional use, and multiple-use equipment.
Show 2 more
  • Commission FAQ guidance supporting documentation for excluded uses, large-scale exclusions, specifically designed equipment, and case-by-case category decisions.
  • Commission FAQ guidance supporting the warnings on professional use, building installations, large-scale exclusions, and components.
"All equipment that has at least one intended function which is dependent on electric current or electromagnetic fields"
More quoted passages
"at least one intended function"
"does not differentiate between EEE for professional or non-professional use"
"case-by-case basis"
"The burden of proof is with the responsible economic operator."
Commission Implementing Decision (EU) 2020/659 on EN IEC 63000
data.europa.eu2 citations
Referenced sections
  • Official source for the RoHS harmonised standard reference used in technical documentation for assessing materials, components, and EEE.
  • Official source for the harmonised standard reference used for RoHS technical documentation assessing materials, components, and EEE.
"technical documentation required for assessing materials"
European Commission - restriction of hazardous substances in electrical and electronic equipment
environment.ec.europa.eu2 citations
Referenced sections
  • Commission overview supporting the plain-language scope summary and the list of ten restricted substances in RoHS.
  • Commission overview supporting the broad RoHS scope statement that products with an electrical and electronic component must comply unless specifically excluded.
"All products with an electrical and electronic component, unless specifically excluded"
More quoted passages
"unless specifically excluded"

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