The recast of the RoHS directive will feature an open scope. The open scope is any electrical and electronic equipment not captured in categories 1 to 10 unless specifically excluded. The scope is divided into eleven categories. Categories 1 to 8 have been in place since July 2006 and categories 8,9 and 11 will follow at different intervals over the next 8 years or so.
Currently excluded products are:
Military and national security equipment, Large-scale stationary industrial tools (LSIT), Transport for people and goods, Equipment for use in space such as satellites, Active implanted medical devices, Photovoltaics, Mobile industrial machinery, Large-scale fixed installations, and Equipment specifically designed solely for R & D including semiconductor development tools
Also, a new exclusion has been agreed that would allow manufacturers of new equipment to use parts from old equipment that had been placed on the market before 1 July 2006. This exclusion will apply only until 1 July 2016 and so will be of little benefit to those products in categories 8, 9 and 11. As the RoHS obligations for these 3 categories are after that date.
After discussions between the EC, EP and Council of Ministers, it was agreed that there should be no additional substances restricted by RoHS but the Commission will carry out reviews of substances for possible restriction using a procedure based on a similar process used for the REACH regulations. Four hazardous substances were identified for priority assessment and possible future ban. It seems likely that some more substances will be added to the list of restrictions but these should be those substances which are proven to have an unacceptable risk to health or the environment and safer alternatives exist.
The 4-year review has been replaced by automatic expiry of all exemptions unless they are renewed. The automatic expiry period has a maximum of five years for categories 1 – 7 and 10 (exemptions in Annex III) and up to seven years for categories 8, 9 and 11 (Annex VI). Applications for exemption renewal must be made at least 18 months before expiry to guarantee a decision from the Commission, which should be made at least six months before expiry. Short transition periods may be granted where requests for renewal are turned down.
Industry will face a significant compliance data collection exercise as it did leading up to 2006. Gathering compliance information was certainly a challenge before and this will become more complex, with potential new product categories falling within scope, as well as changes to exemptions.
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