Understanding the RoHS recast

In the fall of 2010, the European Union agreed to a range of changes to the RoHS directive, known as the “recast”, and these will take effect over the next seven years. The recast will have an open scope with a list of exclusions. The open scope is any electrical and electronic product not captured in categories 1 to 10 unless specifically excluded. The scope is divided into 11 categories and there are different dates when RoHS obligations begin for categories 8, 9, and 11.

Category 8 - Medical equipment (not IVD) will be four years after entry into force
Category 8 - IVD will be six years after entry into force
Category 9 - Consumer Monitoring and control instruments will be four years after entry into force
Category 9 - Industrial Monitoring and control instruments will be seven years after entry into force
Category 11 - “Open scope” will be eight years after entry into force

Currently, the list of excluded products includes:

• Military and national security equipment - not defined but the same as at present
• Large-scale stationary industrial tools (LSIT) - these are large-scale manufacturing plant such as oil refineries, production lines, etc and this exclusion is the same as the current LSIT exclusion.
• Transport for people and goods - aircraft, trains, commercial vehicles, buses, vans, cars, ships and boats and any electrical equipment that is designed to be used as integral parts of these forms of transport. The only exception is two wheeled electric bicycles which will be in scope.
• Equipment for use in space such as satellites - previously assumed to be excluded so this clarifies the status.
• Active implanted medical devices - (pacemakers, etc.)
• Photovoltaics - commercial electricity generation systems, not consumer products
• Mobile industrial machinery - a new exclusion that covers only professional equipment so would exclude from the scope of RoHS some equipment such as commercial electric lawnmowers designed for golf courses and public spaces which are currently in scope.
Large-scale fixed installations - a new exclusion which is intended to clarify the status of fixed installations. Currently the status of fixed installations is very unclear with each Member State having its own interpretation.

The following will probably be excluded:
• Railway network signalling
• Traffic lights and other road equipment
• Alarm systems and HVAC in large factories and large office buildings
• Wiring, switches, sockets, circuit breakers fuses, etc. but only where they are used in large-scale fixed installations

• Equipment specifically designed solely for R&D - this would exclude semiconductor development boards. This has been the subject of great debate in Europe, especially the low cost PCB based evaluation tools. Cables will be in scope whereas consumables continue to be excluded.

Also excluded, as at present is any equipment designed to be used as integral parts of any products such as those listed above, that are excluded from scope.

For those wishing more detail and explanation, I have written a new e-book on RoHS that you can download here.