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.

Both placement dates must match the relevant Article 4(5) branch below: the EEE from which the part was recovered and the recipient EEE. The recipient cutoff is a date for placing that EEE on the market, not a deadline for carrying out a later repair.

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 entry 31a covers lead, cadmium, hexavalent chromium, and polybrominated diphenyl ethers (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 lists expiry dates of 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. A printed expiry date alone does not establish current validity: check timely renewal and any Commission decision before relying on the entry.

Annex IV entry 47 covers bis(2-ethylhexyl) phthalate (DEHP), butyl benzyl phthalate (BBP), dibutyl phthalate (DBP), and diisobutyl phthalate (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.