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RoHS: the Revision

The European Union has adopted the Recast of the RoHS Directive, RoHS II, and the official text was published June 8, 2011. This page provides information specific to the review of the RoHS Directive. If you are looking for background information on RoHS, please click here.

RoHS II made several important changes.

First, the scope of RoHS II was expanded. “Electrical and electronic equipment” (EEE) now includes equipment which is dependent on electric current or electromagnetic fields for at least one intended function. The previous Directive only applied to equipment that depended on electric current or electromagnetic fields for its primary function.

RoHS II also added three new categories of EEE: medical devices, monitoring and control equipment, and “all EEE not covered by any other category.” Medical devices and monitoring and control equipment are included as of 2013, and the catch-all category will be included in 2019.

Second, the exemptions process has been amended. RoHS II clearly establishes three categories of exemptions: exemptions for technical applications of all categories of EEE, exemptions for medical devices, and exemptions for monitoring and control instruments. The automatic review process has been abolished, and now industry must request an exemption renewal 18 months before expiry. All exemptions, except for those applying to medical devices and monitoring and control instruments, are subject to a 5 year time limit.

Third, RoHS II has implemented a CE marking requirement. This means that each product must have technical testing and accompanying documents, a declaration of conformity, and the CE marking affixed to the product.

Timeline

Member States are given until January 2013 to transpose the Directive into national legislation.

The text of RoHS II is available at the following link.

We are always interested to receive information from U.S. companies, and to see what U.S. companies are sending to the EU institutions. If you wish to copy us on such correspondence, please use the following email address: Office.BrusselsEC@trade.gov