Pallets under EU REACH and EU RoHS

Question:

Are pallets considered in scope of the Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH) Regulation and the Restriction of Hazardous Substances (RoHS) Directive?

Answer:

Pallets are considered out of scope of RoHS because they do not meet the definition of electrical or electronic equipment (EEE). However, they would be in scope of REACH as articles, as noted in the following guidance: “The packaging is not a part of the substance, mixture or article being packaged. It is, therefore, to be considered as a separate article under REACH and the same requirements apply to it as for any other article.”

 

Reference: https://echa.europa.eu/documents/10162/23036412/articles_en.pdf

**Article contents valid as of 2019-03-18

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