EU RoHS Scoping Example: Electronic Lockset Kit

Determining the scope of the European Union (EU) Restriction of Hazardous Substances (RoHS) Directive depends on correctly defining electrical or electronic equipment (EEE), which may be difficult for products containing multiple parts. As an example, consider an electrical lockset, which also includes a strike and latch assembly for attachment to the door. The electronic lock itself is clearly EEE, but what about the strike and the latch assembly?

Our interpretation is that the latch assembly, which is likely made specifically to function with this model of lock, should be considered EEE. However, the strike plate does not need to be considered EEE. A strike plate is not part of the lockset but is installed on the jamb, and it can also function as part of a non-powered lock kit.

This conclusion is based on the European Commission's FAQ document for the EU RoHS Directive, which gives a detailed definition and several examples of EEE:

Q7.1 Is my product EEE as per Articles 3(1) and (3)2?
There are two elements clarifying the meaning of EEE in RoHS 2:
- a general definition of EEE in Article 3(1);
- a definition of “dependent” in Article 3(2).

All equipment that has at least one intended function which is dependent on electric current or electromagnetic fields, or that generates or transfers or measures such currents and fields is EEE. Even if the electric function is only a minor element of the equipment, the definition still applies.

Indicative examples of such EEE are:
- a gas cooker with an electrical clock;
- a singing teddy bear;
- sport shoes with lights;
- petrol powered equipment with an electric spark for ignition, like lawnmowers.

In all these cases the electric function is an intended and integral part of the product’s functionality, and the full functionality of the equipment is at least impaired (i.e. it does not work properly) if that electrical function fails. It is irrelevant where the electricity comes from, or if it is the main energy source.

The door itself would also not be considered EEE, because it can be used separately from the electrical portion of the lock. (If the lock were removed, the door would still be a functional door.) This is based on the same FAQ document:

For the example of a wardrobe with lights, even if sold as a single unit, a distinction between the piece of furniture and the electric/electronic device the piece is or can be equipped with has to be drawn. If the lighting is EEE in itself and both the lighting and the wardrobe can be separated and used as fully functional separate products, only the electric/electronic equipment (the lighting) is in the RoHS 2 scope. The furniture itself would then be outside the scope.

Source: EU RoHS Frequently Asked Questions (European Commission)

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