EU RoHS Compliance: Components vs. Finished Products

Question: Do European Union (EU) Restriction of Hazardous Substances (RoHS) Directive requirements apply to finished products, or to their component parts? 

Answer: If a product is in scope of EU RoHS, all of its component parts must be compliant.  If the components are all compliant, then the final product is compliant. 

The EU RoHS Directive requires electrical and electronic equipment (EEE) to be compliant at the homogeneous material level. Compliance is calculated at that level and then "rolled up" through the component level to make the final product compliant. 

Exemptions may be leveraged(if applicable for the specific use) to make a product compliant. This is called being compliant by exemption. However, exemptions are applied at the product level (depending on use), meaning some components may not meet the requirements of the directive. 

If restricted substances are present in a product above threshold without an exemption, that product cannot receive the CE marking or be placed on the EU market.

Article is current as of 2019-04.

Reference(s): 

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/679655/rohs-directive-guidance.pdf

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