EU RoHS: Defining Large-Scale Stationary Industrial Tools

Question: How are EU Restriction of Hazardous Substances (RoHS) Directive exclusions for large-scale stationary industrial tools (LSSIT) and large-scale fixed installations (LSFI) determined and documented? What does “large scale” mean in this context?

Answer: Article 2(4) of the RoHS Directive has a list of equipment that is excluded from its scope. Two of these are LSSIT and LSFI. Page 9 of the RoHS 2 FAQ document provides details on what these two exclusions mean, but the term “large scale” is not defined. The onus is placed on the company that wishes to take advantage of these exclusions to justify why they think their “stationary industrial tool” or “fixed installation” is large scale. The member state enforcement authority may challenge the company’s justification if they disagree.  

One should err on the side caution when determining exclusions purely to benefit the business, since authorities will apply their own interpretation to better protect their citizens and the environment through reduction of hazardous substances.

 

Content is current as of 2020-01-24.

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