Clarity on Article 7

I have taken many questions around Article 7(h) of the RoHS Recast. Here are the thoughts of Dr Paul Goodman of ERA Technology:

Article 7h is quite clear – manufacturers must put their contact details on electrical products. If the manufacturer is located outside the EU, then the importer must also affix their contact details, and according to the enforcers, the addresses of both would be required.

There are three other things to note. i) EU enforcers cannot force non-EU manufacturers to do anything, they can only regulate EU-based legal entities. ii) more usefully, non-EU manufacturers may appoint an authorised representative in the EU to take on many of their obligations, including 7h (see article 8). If this is also the importer, then only one contact detail is needed. Lastly (iii), in the circumstances where the equipment is sold under the badge of a customer if they are in the EU, then the EU importer is regarded as the manufacturer (article 11) and so only their contact details would be required”.

 

Directive Decoder

Tags: circumstances, clarity, electrical products, legal entities, rohs

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