As you know, EU RoHS is supposed to be a single market directive, in other words the interpretation is the same across all Member States (Article 95). However, one or two differences are already becoming apparent.
The scope is still being discussed by the European Commission and the Technical Adaptation Committee (TAC) with the status of "fixed installations", cables and luminaires remaining unclear.
Variations in approach include Holland, for example, where car radios sold to users are considered in scope contrary to the EC's published guidance.
Elsewhere, equipment such as electric heaters and air conditioning that is bolted to walls is regarded as being in scope by some Member States but outside scope by others.
The status of large industrial machines is also unclear, regarded by some as large-scale stationary industrial tools (out of scope) and by others simply as tools and so in scope.
However, with all this in mind the EC is pressing on with a review of the future scope of RoHS.
This column understands that topics for discussion could include product groups, such as the category 8 and 9 review undertaken by ERA Technology.
Adaptation of the list of restricted substances which, in theory, could mean adding, or removing from the current list.
The scope of RoHS, which is currently based on the scope of the WEEE Directive, but does it need to be and are there better ways of defining the scope?
So, whether you are looking back, or looking forward on EU RoHS, many questions still remain unanswered.
Directive Decoder
Gary Nevison, Head of Legislation at 
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