Do the Eurasian Conformity (EAC) RoHS (also known as “Russia RoHS”) regulations apply to a winch to be installed as an accessory on a vehicle?
The following are EAC RoHS in scope products:
- Household electrical equipment.
- Electronic computers and devices connected to them, including their combinations.
- Telecommunication terminal.
- Copy machines and office electrical equipment.
- Electric power tool.
- Lighting equipment, including that embedded in furniture.
- Electric music instrument.
- Gaming machine and vending machine.
- ATM, ticket printing machine, ID card readers, etc.
- Cables, wires and cords for use at rated voltages less than 500 VAC and (or) DC, except fiber optic cables.
- Automatic switches and protective devices.
- Fire, security and fire-alarm detectors.
Specifically excluded (Out of Scope) products are:
- Products designed for use at nominal voltage exceeding 1000 V AC or 1500 V DC unless otherwise provided in Annex 1.
- Products designed solely for use as components of electrical and electronic equipment that are not listed in Annex 1.
- Electric toys.
- Photovoltaic panels/solar panels used as part of the electrical and electronic equipment.
- Products designed to be used in land-based and orbiting space objects.
- Products intended solely for the use of air, water, ground and underground transport.
- Batteries and accumulators, including those put into circulation on the territory of the CU as part of electrical products.
- Used electrical and electronic equipment.
- Measuring instruments.
- Medical devices.
A winch could possibly fall under “Electric power tool”, item number 5 (In Scope products).
It is possible that they could be excluded under exclusion 6, “Products intended solely for the use of air, water, ground and underground transport” along with exclusion 2, “Products designed solely for use as components of electrical and electronic equipment that are not listed in Annex 1”, but it would need to be solely for use of that product.
It is not specified if accessories count as a component, but one could make a case that it is, so long as it can only work when on the vehicle. Provided that this is the case, it could be out of scope.
**Article contents valid as of 2018-09-04