Defining “Large-Scale Stationary Industrial Tools” and “Large-Scale Fixed Installations” under EU RoHS

Question Posed:

Could you please elaborate on how industrial equipment is defined under EU RoHS? How are the exempted categories defined under 2011/65/EU, Article 2 (d) and (e), namely large-scale stationary industrial tools and large-scale fixed installations?

Answer Provided:

Under the EU RoHS FAQ, question 3.1, the following clarification is provided:

“‘Large-scale stationary industrial tools’ and ‘large-scale fixed installations’ are combinations of various types of items, such as machinery, components etc. for permanent use at a specific place, installed and de-installed by professionals.

Tools are essentially machines, stand-alone or assemblies, often with moving parts, and used for example for the treatment or manufacturing of materials and work pieces. The Machinery Directive can be used as guidance. Typical machine tools can also be part of fixed installations.

In order to benefit from either exclusion the tool or installation must meet all the respective requirements. As stated below, it has to be:

(A Tool)

  • an assembly of machines, equipment and/or components, functioning together for a specific application;
  • permanently installed and de-installed by professionals at a given place;
  • used and maintained by professionals in an industrial manufacturing facility or R&D facility;
  • and it has to be large-scale;

(An Installation)

  • a combination of several types of apparatus and, where applicable, other devices;
  • assembled, installed and de-installed by professionals;
  • with the intention to be used permanently in a pre-defined and dedicated location;
  • and it has to be large-scale.

"Large-scale" is part of both sets of requirements. Evidently, this draws a line between "larger" tools and installations benefiting from an exclusion, and otherwise similar, "smaller" equipment. "Large-scale" refers to dimensional or similar criteria as explained below, although this criterion is not specified in the RoHS 2.’”

Reference: http://ec.europa.eu/environment/waste/rohs_eee/pdf/faq.pdf

**Article contents valid as of 2017-06-15

 

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