RoHS FAQ Spare Parts

Start with the exact role of the part. RoHS defines a spare part as a separate part of EEE that can replace a part of EEE, where the EEE cannot function as intended without it and functionality is restored or upgraded when the part is replaced.

Article 4(4) keeps the restriction from applying to cables or spare parts used to repair, reuse, update functionality, or upgrade capacity of specified legacy EEE. The relevant legacy dates are: EEE placed on the market before 1 July 2006; medical devices before 22 July 2014; in vitro diagnostic medical devices before 22 July 2016; monitoring and control instruments before 22 July 2014; industrial monitoring and control instruments before 22 July 2017; and other EEE newly brought into RoHS scope before 22 July 2019. These are placing-on-the-market dates for the supported EEE, not manufacture dates for the replacement part.

There is also a narrow exemption for EEE that benefited from an exemption and was placed on the market before that exemption expired, but only as far as that specific exemption is concerned. That makes the exemption entry, expiry date, product placement date, and spare-part use case essential facts.

Article 4(5) is narrower than the general spare-part transition rule. It applies only where reuse happens in auditable closed-loop business-to-business return systems and the reuse of spare parts is notified to the consumer.

For reused spare parts, the recovered-from and used-in dates must both fit the Directive. Reused parts recovered from EEE placed on the market before 1 July 2006 could be used in EEE placed before 1 July 2016. Reused parts recovered from medical devices or monitoring and control instruments placed before 22 July 2014 could be used in EEE placed before 22 July 2024. Reused parts recovered from in vitro diagnostic medical devices placed before 22 July 2016 could be used in EEE placed before 22 July 2026. Those three used-in deadlines have passed. The remaining future cutoffs are before 22 July 2027 for reused parts recovered from industrial monitoring and control instruments placed before 22 July 2017, and before 22 July 2029 for reused parts recovered from other EEE that was outside RoHS 1 scope and placed before 22 July 2019.

Article 4(6) excludes applications listed in Annex III and Annex IV from the Article 4(1) restriction. Those exemptions are application-specific and time-limited; they should not be treated as product-wide approval.

Some Annex IV entries expressly mention spare parts. For example, Annex IV includes an entry for lead, cadmium, hexavalent chromium, and PBDE in recovered spare parts used for repair or refurbishment of certain medical devices, in vitro diagnostic medical devices, or electron microscopes, with auditable closed-loop B2B reuse and customer notification. That entry expired on 21 July 2021 for medical devices other than in vitro diagnostic medical devices, 21 July 2023 for in vitro diagnostic medical devices, and 21 July 2024 for electron microscopes and their accessories.

Annex IV also includes a later entry for DEHP, BBP, DBP, and DIBP in spare parts recovered from and used for repair or refurbishment of medical devices, in vitro diagnostic medical devices, and their accessories, under the same closed-loop and notification conditions. The consolidated Directive lists that entry as expiring on 21 July 2028.

A useful spare-parts decision file should let a reviewer re-run the RoHS logic without interviewing the service team. The key facts are the spare part identity, supported EEE identity, product category, placement dates, whether the part is new or recovered, and the exact legal route used.

For ordinary compliant spare parts, keep supplier declarations, material declarations, restricted-substance assessment, and any test evidence used to assess homogeneous materials. For transition or reused-part cases, add placement-date evidence, return-system controls, customer notification proof, and the Annex exemption register if an exemption is being relied on.