The obligations for category 11 products differ slightly from those of other categories.
There is no allowance to use non-compliant spare parts in pre 2019 equipment. RoHS also applies to category 11 products made available from 23 July 2019 and not, as with other product categories that must comply if placed on the market after the relevant deadline. Therefore, old non-compliant “category 11” stocks cannot be sold after 23 July 2019, regardless of when they were made or imported into the European Union.
Article 2(2) of Directive 2011/65/EU states:
Without prejudice to Article 4(3) and 4(4), Member States shall provide that EEE that was outside the scope of Directive 2002/95/EC, but which would not comply with this Directive, may nevertheless continue to be made available on the market until 22 July 2019.