The use of low cost development kits has increased dramatically over the last few years. There is no doubt that these low cost plug-in PCBs are a great tool for the design engineer. The boards essentially demonstrate the capabilities of the specific device for which they are designed.
However, there has been much debate around their status in respect of the RoHS Directive and, more importantly, the impact of the RoHS Recast 2011/65/EU and the implications of the CE mark.
There has been uncertainty in industry and indeed development kit manufacturers around whether or not they are deemed to be finished products and, if so, which category should they fall in?
The “Blue Guide” which is the European Commission’s guidance on how to implement new approach directives implies that finished equipment is product where no further assembly is necessary except to plug it in to allow it to carry out its function. An enclosure is not a requirement for equipment to be “finished”. Development boards are clearly finished products according to the Blue Guide’s definition as they are simply plugged in to other equipment to make them work.
RoHS enforcement bodies across Europe regard development boards as being in scope, and generally category 3 as these are often marketed as “single board computers”. Others, with no IT function, such as stepper motor controller chips are captured under category 9. Such an example would be in scope from 22 July 2014. If the function of the development kit does not align with one of the RoHS categories then there are no immediate obligations but it is worth bearing in mind that the Open Scope Category 11 captures all EEE from 23 July 2019 unless specifically excluded.
Under the RoHS Recast there is an exclusion for equipment designed solely for R&D (refer to FAQ4.2 for further guidance). Semiconductor development board manufacturers may have hoped that this would exclude development kits but this is not the interpretation of the RoHS “FAQ” guidance committee who represent Member State Governments. Their opinion is that this exclusion applies only to equipment which has been constructed for which research will be carried out and does not exclude equipment used to carry out research into other equipment designs.
It is clear that EU Member States regard development kits as finished equipment and as being in scope. They needed to comply with CE marking obligations for product placed on the market after 2 January 2013.
Development tools sold as “a bag of bits” and a PCB also fall within scope. Again the Blue Guide is useful and states “a combination of different products and parts designed or put together by the same person is considered as one finished product which, as such, has to comply with the directive”.
Many manufacturers of development boards have made them compliant with the directive but, historically, there have been several notable exceptions that have had to work on ensuring their products comply. Depending on function and when they fall in scope, manufacturers need to provide all the necessary documentation as part of their CE obligations.
Remember the original Raspberry Pi back in 2012 that was just caught in time as no-one realised that compliance work was needed. Five weeks later it was ready for launch.
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