Directive Decoder

One topic that was the subject of much debate was the decision of UK enforcement authority NWML to consider Semiconductor Evaluation Boards as within the scope of EU RoHS. Their website states:
The term "Evaluation Boards" covers a broad range of products from those that are fairly simple through to fully integrated complex systems. In most cases an evaluation board is effectively a single board computer allowing connection of peripherals and / or input devices to facilitate the programming and testing of chips. Therefore, most evaluation boards are included under Category 3 -IT Equipment- of the WEEE Directive and must comply with RoHS.
Fair enough although it did catch some manufacturers out.

So what about electronic kits for self assembly?
I was having a chat about this with my good friend, and global RoHS expert, Paul Goodman at ERA Technology.
He felt that it depended on the function of the parts and who does the assembly.
Thinking this through, if assembly is carried out by anyone other than the user, then the status will depend on the function of the assembled product. Clearly, if parts are sold to the user, each part needs to be assessed, not the assembled product. This is because the EU RoHS Directive applies to "finished products" that are "Put Onto The Market". POTM is defined by the "Blue Guide" which says that a product has NOT been POTM if further assembly work is required.

Drop me a line if your business is involved with either semicondutor evaluation boards or electronic kits for self assembly.

Directive Decoder