| Scope and covered activity | RoHS applies to EEE falling within Annex I categories and uses the EEE definition based on dependence on electric currents or electromagnetic fields for at least one intended function. | The RoHS FAQ states that batteries and accumulators used in EEE are not within RoHS; this page does not source detailed Batteries Regulation scope rules. | Classify the finished EEE under RoHS, then open a separate battery-law scope record for the battery rather than stretching the RoHS conclusion. |
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| Who must act | RoHS names manufacturers, authorised representatives, importers, and distributors as economic operators, with manufacturer duties for design, technical documentation, EU declaration, CE marking, corrective action, and authority cooperation. | The cited RoHS sources support the EEE economic-operator map, not a detailed Batteries Regulation actor map. Treat battery-law ownership as unresolved until a battery-specific source is reviewed. | Assign RoHS duties to the EEE economic-operator owner and assign a separate owner to obtain and maintain battery-law evidence. |
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| Trigger or threshold | RoHS is triggered by placing covered EEE on the EU market and by assessing whether its homogeneous materials exceed Annex II maximum concentration values or rely on an exemption. | For batteries, the supported trigger here is only negative: the RoHS file should not be used as the battery-law trigger analysis. | Use intake questions that route the same product to RoHS for EEE substance restrictions and to a separate battery-law review for the battery. |
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| Core obligations | RoHS requires manufacturers to ensure EEE is designed and manufactured in accordance with Article 4, draw up technical documentation, carry out internal production control, draw up an EU declaration of conformity, and affix CE marking when conformity is demonstrated. | Battery-specific design, labelling, due-diligence, waste, or passport duties are not established by the RoHS sources cited here and should be handled in a separate battery-law record. | Build a RoHS action list from Article 4 and Article 7, then add battery-law actions only after a separate Batteries Regulation source review. |
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| Evidence and records | RoHS evidence should include the EEE scope decision, homogeneous-material assessment, Annex II substance matrix, exemption record where used, supplier declarations, relevant test or assessment evidence, EN IEC 63000 technical documentation, EU declaration of conformity, and change records. | Battery evidence may sit in the same product compliance pack, but this RoHS grounding does not define the battery technical file or record set. | Use a shared index only if each record is tagged as RoHS evidence, battery-law evidence, or background support. |
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| Timing and cadence | RoHS timing includes the market-placement point, 10-year availability of technical documentation and EU declarations for relevant economic operators, exemption renewal applications no later than 18 months before expiry, and review when standards, design, or suppliers change. | Do not infer Batteries Regulation application dates or transition periods from the RoHS folder. | Track RoHS release and retention dates separately from any battery-law milestones obtained from battery-specific sources. |
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| Enforcement or assurance route | RoHS non-conformity can require corrective measures, withdrawal or recall where appropriate, notification to competent national authorities, and cooperation with authority requests for information and documentation. | Battery-law enforcement routes need a battery-specific source before they are added to the product compliance plan. | Authority-response playbooks should run two tracks: RoHS track for EEE-substance CE/DoC and Article 7 technical-control issues, and a separate Batteries Regulation track for battery claims, battery waste, and battery-duty questions. Escalate battery-law inquiries to a designated battery-law owner and only proceed to authority communication after that owner confirms source-linked battery evidence. |
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| Overlap and reuse | RoHS can reuse supplier and material evidence only where it demonstrates the RoHS Article 4 substance conclusion for the covered EEE, component, cable, or spare part. | Battery-law teams may reuse supplier information as background, but this page cannot say that RoHS declarations satisfy Batteries Regulation duties. | Avoid customer-facing statements that say a RoHS declaration proves battery compliance; state the RoHS conclusion and cite a separate battery source for any battery claim. |
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| Practical decision rule | Proceed under RoHS when the immediate question is EEE scope, Annex II substance limits, exemptions, CE marking, EU declaration, technical documentation, or market-surveillance evidence. | Proceed under a separate Batteries Regulation review when the question is about the battery itself, battery waste, battery-specific documentation, or battery-specific market duties. | For combined products, run both workstreams only after confirming the RoHS EEE boundary and obtaining battery-specific source support for battery duties. |
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