Question: My company produces fuel delivery modules (FDMs). Because we sell it into India, we need to understand India Restriction of Hazardous Substances (RoHS) lead restrictions. It does not appear that our product is in scope, but we need to be certain. Can you help?
Answer: India RoHS, and the Waste Electrical and Electronic Equipment Directive, include a limited list of products that are considered in scope as defined in Schedule 1 of the updated India E-Waste Management Rules, GSR 338(E), March 2016. It includes the original six RoHS substances, but not the four phthalates added to RoHS 2 (EU 2015/863) this year. The list of products does not make specific reference to FDMs or any similar products, so I would agree that you are not within the scope of India RoHS.
You are, however, in scope of the European Union (EU) RoHS Directive — most likely under Category 11 — and must ensure this product is either compliant with all 10 substance restrictions, or has received an exemption.
Source: E-Waste (Management) Rules, 2016 (includes a link to a PDF of the GSR 338(E) regulation itself)
Content current as of 2019-09-13.