EU interpretation on “dev kits”
You may have read articles in the US that tend to suggest semiconductor based evaluation boards do not fall within the scope of the RoHS Directive. That might be the case if just shipped within the US but, once exported into Europe, it is a different matter.
The use of low cost semiconductor evaluation boards, normally referred to as “development kits” has increased dramatically over the last few years. There is no doubt that these low cost plug-in PCBs are a great tool for the design engineer. The boards essentially demonstrate the capabilities of the specific device for which they are designed.
However, there has been a long running debate around their status in respect of the RoHS Directive and, more importantly, the impact of the RoHS Recast 2011/65/EU and, in particular, the implications of the CE mark.
There has been uncertainty in industry and indeed development kit manufacturers around whether or not they are deemed to be finished products and, if so which category should they fit in?
The “Blue Book” which is the European Commission’s guidance on how to implement new approach directives implies that finished equipment is product where no further assembly is necessary except to plug it in to allow it to carry out its function. An enclosure is not a requirement for equipment to be “finished”. Development boards are clearly finished products according to the Blue Guide’s definition as they are simply plugged in to other equipment to make them work. Enforcement Authorities also regard plug-in graphics cards and the likes as being finished products as they are sold to end-users who simply plug them into slots on their PCs.
RoHS enforcement bodies across Europe regard development boards as being in scope, and generally category 3 as these are often marketed as “single board computers”. Others, with no IT function, such as stepper motor controller chips are captured under category 9.
Under the RoHS Recast there is an exclusion for equipment designed solely for R&D. Semiconductor development board manufacturers may have hoped that this would exclude development kits but this is not the interpretation of the RoHS “FAQ” guidance committee who represent Member State Governments. Their opinion is that this exclusion applies only to equipment which has been constructed for which research will be carried out and does not exclude equipment used to carry out research into other equipment designs.
It is clear that EU Member States regard these as finished equipment and as being in scope. They will need to comply with CE marking obligations for product placed on the market after 2 January 2013.
Development tools sold as “a bag of components” and a PCB also fall within scope. Again the Blue Book is useful and states “a combination of different products and parts designed or put together by the same person is considered as one finished product which, as such, has to comply with the directive”.
Many manufacturers of development boards make them RoHS compliant but there are several notable exceptions that now need to work on ensuring their products are compliant and, from January, actively provide all the necessary documentation as part of their CE obligations.
Maybe there will be a challenge through the courts one day but, in the meantime, plug-in boards such as Raspberry Pi need to be compliant.