Even though the RoHS Directive was implemented over two years ago I still get asked about the status of Semiconductor Evaluation Boards or Evaluation Kits as they are widely known.
These kits are often very low cost and simulate the performance of a chip in a particular environment, often a microcontroller. The more complex kits also offer a programming facility.
While the more expensive programmers were fully encapsulated pieces of equipment and clearly within the scope of the directive, many were simple open circuit boards, so were they in scope?
At
that time even environmental lawyers sat on the fence while
manufacturers clearly thought that such a primitive product was not. It
came as a shock when the UK Enforcement Agency, NWML, offered some
clarity through the frequently asked questions area of their website.
They said:
"The
term Evaluation boards covers a broad range of products from some
fairly simple products 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 therefore comply with RoHS. On rare occasions these boards may be
considered consumables and fall outside the scope of RoHS as described
in the commission FAQ"
Gary Nevison, Head of Legislation at 
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