EU RoHS: Product Categories for Component Parts

Question: My company produces a part (a cellular modem) which is sold to our customer, who incorporates it into their final product (an electric metering device). Under EU RoHS, does our product belong to Category 3 (as a modem) or Category 9 (as an electric metering device)?

Answer: Generally speaking, the final product type is the category that applies at any given point. If your modem is sold as a stand-alone item, it would belong to Category 3 at that point. Once it is used to build the electric metering device, that final product will belong to Category 9. 

It's important to consider where in this process the product is sold to a customer on the EU market (or "placed on the market," to use the terminology from EU RoHS). If your customer is in the EU, then your modem will likely be a Category 3 product when you sell it to them, and then part of a Category 9 product when they sell their electric metering device. If your customer is not in the EU, however, your initial sale to them is not in scope for EU RoHS. In this case, no category will apply to your modem until your customer places their final electric metering product on the market in the EU, at which point your modem will be part of a Category 9 product.

Article current as of 2020-04-17.


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