FAQ item index

Search every question across sub-FAQs

Find the exact question, open the source answer card, and copy a direct link to the anchored sub-FAQ response.

Indexed coverage
42of42items
Across 10 modules • Updated May 9, 2026
Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Back to sub-FAQs
Which EEE is in scope under EU RoHS?

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, SKU, configuration, voltage rating, photographs or diagrams, and the EEE function that depends on electricity or electromagnetic fields.
  • Market facts: who places it on the EU market, whether it is finished EEE, 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: 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 EEE 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.
Citations
Jump to answerOpen module
Which EEE is in scope under EU RoHS?

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 EEE; 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.
Citations
Jump to answerOpen module
Page 3 of 3
Previous123Next