Question: As an industrial coatings manufacturer, do I fall into the scope of RoHS?
Answer: All components of a product defined as Electrical and Electronic Equipment (EEE) must comply with EU RoHS. Because industrial coatings may be used on (and thus be a component of) products that are in the scope of EU RoHS, the industrial coatings must be in compliance with the Directive.
If you know that you do not use any of the restricted substances it's fairly easy to answer inquiries about RoHS compliance, but it's still important to maintain documentation to support that claim in case of auditing. If your product does contain any of the restricted substances, you must meet the appropriate restrictions under RoHS.
Here's some more specific information about components under RoHS:
Q7.3 Do components have to comply with RoHS 2?
RoHS 2 provides that Electrical and Electronic Equipment (EEE) has to meet the requirements of the Directive. Since equipment consists of different components, the EEE itself can only meet the substance requirements if all its components and parts meet the substance restriction requirements of RoHS 2, including non-electronic or non-electric components like fasteners or the plastic case of a desktop computer. Therefore components being used in finished EEE or for repair or upgrade of used EEE, which is in the scope of RoHS 2 must meet the substance restrictions according to Art. 4 but do not need CE marking.
Article content current as of 2018-05-25.