RoHS impact assessment

The third stakeholder meeting looking at the impact assessment with regard to potential changes in scope to the new RoHS Directive recently took place in Brussels.

Article 2.2 effectively puts a stop to the sale of any product that does not comply with the directive after 22 July 2019, and it was stressed that this includes medical devices and monitoring and control instruments that fall into scope from 2014 onwards.

On the subject of furniture with secondary electrical functions the stakeholders were advised of the new position of the European Commission. In the case of a wardrobe with a light in which the latter is separable and fully functional on its own, the light will be the EEE but not the wardrobe. Furniture with primary electrical functions, such as a reclining chair or bed is already in the scope of RoHS.

During the meeting it was confirmed that passenger lifts will be considered large-scale fixed installations and would therefore be excluded from the scope of the RoHS Recast. It was also recommended to exclude pipe organs and electric bicycles from scope in the future. However, petrol engine powered garden equipment and toys with secondary electrical functions are expected to fall within scope.

While no change to the definition of homogeneous material was deemed necessary further clarification was requested on both thin coatings and CrVI passivation coatings.

The final report of this project is due in July 2012.

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