EU RoHS and Aerospace Companies

Question: Are aerospace companies in scope of the European Union (EU) Restriction of Hazardous Substances (RoHS) Directive?

Answer: In general, aerospace companies will be out of scope of EU RoHS because their products fall within an exempt category (products used as a mode of transportation). This exemption applies to many aviation products, such as aircraft/engines.  

The situation is more complicated, however, in the case of multi-use products. Items like common connector modules, display screens, monitors, or sensors may be used in multiple industries, including in products or situations that would not fall under the transportation exemption. Electrical and electronic equipment (EEE) that is designed to have at least one use that is in scope of RoHS must comply with the directive. 

For instance, aerospace companies might need to provide RoHS compliance information if multi-use EEE products are sold for spare parts. Since these parts may end up being used outside of the aerospace or transportation industry, EU RoHS compliance could potentially be required. 

For more information, see the European Commission's RoHS 2 FAQ.

Article is current as of Feb. 2019.

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