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 and must be able to fulfil its function only as part of that 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.
Primary legal source for the EEE definition, Annex I categories, Article 2 exclusions, Article 4 restriction rule, and manufacturer documentation duties.
Commission overview supporting the broad RoHS scope statement that products with an electrical and electronic component must comply unless specifically excluded.
Commission FAQ guidance used for practical scope examples on intended electrical functions, multiple-use products, components, cables, consumables, and large-scale exclusions.