Are consumables in scope of RoHS2?

A lot of people are asking about the RoHS Recast that will be transposed into national law by 2 January 2013.

A question frequently raised is around the status of “consumables” and whether or not they are in scope.

The European Commission FAQ document, question 6.1 offers useful guidance:

“Consumables that have no equipment constituent, such as soap powder or vacuum cleaner bags, are not equipment and are therefore not in the scope of RoHS2. Only consumables with an equipment constituent meeting the definition of EEE in Article 3(1) and 3(2) such as printer cartridges are EEE and therefore in the scope of RoHS2″

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