RoHS: Category Designation for Complex Products

Question: My company uses parts that are only RoHS 2 compliant, due to being Category 9 products used in the manufacture a Category 11 products in scope of RoHS 3. Do I treat the subpart as Category 9 or 11? 

Answer: The final assembly defines which category the product falls under. So even if a subpart is defined as Category 9, it is required to be compliant when added to a Category 11 product. If the Category 9 subpart were sold as a standalone product on the EU market, it could use the Category 9 extension for RoHS 2 amendment (EU) 2015/863 for the four phthalates (sometimes referred to as RoHS 3).

All sub-parts in a Category 11 assembly must comply with requirements for all 10 substances defined under EU RoHS 2 2011/65/EU and amendment (EU) 2015/863.

Content is current as of 2019-10-25.

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