RoHS and Tapes, CDs, or Other Digital Storage Media

Question: Would tape cartridges that must be placed in an electric drive or writer to function be in-scope for RoHS? What about CDs, computer disks, DVDs, etc.?

Answer: The Restriction of Hazardous Substances (RoHS) Directive applies to all electronic and electrical equipment (EEE) dependent on electric current or electromagnetic fields for at least one intended function. On the surface this may seem to exclude digital storage media, and in fact the issue of consumables under RoHS has generated significant discussion since RoHS has been in force.

The considered view of most EU member states is that items like tape media (and printer cartridges, another common example) are in scope for RoHS. These items fall within the definition of EEE given in RoHS Article 3(1), since they do depend on electric current or electromagnetic fields to function properly. 

The European Commission's "RoHS 2 FAQ" concludes that consumables (such as printer cartridges) are in-scope for RoHS. This further demonstrates that the RoHS definition of electronic and electrical equipment (EEE) includes items whose dependence on electric current or electromagnetic fields is indirect.

Article current as of 2019-11-08.

References:

Definition of Electronic and Electrical Equipment (EEE), RoHS Article 3 (1)

RoHS 2 FAQ, specifically Q7.4 (PDF)

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