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Guidelines for the EU Directive on RoHS 2


On November 21, 2017, the EU published Directive 2017/2102 to amend 2011/65/EU on RoHS 2. The Directive came into force since December 11, 2017.


According to (EU) 2017/2102, the main amendments for Directive 2011/65/EU are as follows:


1. Pipe organs was excluded from the scope of RoHS 2.


2. The definition of “non-road mobile machinery made available exclusively for professional use” is amended. Now it means machinery, with an on-board power source or with a traction drive powered by an external power source, the operation of which requires either mobility or continuous or semi-continuous movement between a succession of fixed working locations while working, and which is made available exclusively for professional use.


3. The Directive will apply to all other EEE that have been excluded from Directive 2002/95/EC and placed on the market before July 22, 2019. The exemption period for the category is up to 5 years.


4. Restrictions will not apply to the parts:


a) Recovered from EEE placed on the market before July 1, 2006 and used in EEE placed on the market before July 1, 2016.

b) Recovered from medical devices or monitoring and control instruments placed on the market before July 22, 2014 and used in EEE placed on the market before July 22, 2024.

c) Recovered from in vitro diagnostic medical devices placed on the market before July 22, 2016 and used in EEE placed on the market before July 22, 2026.

d) Recovered from industrial monitoring and control instruments placed on the market before July 22, 2017 and used in EEE placed on the market before July 22, 2027.

e) Recovered from all other EEE that was outside the scope of Directive 2002/95/EC and which is placed on the market before July 22, 2019, and used in EEE placed on the market before July 22, 2029.


5. For the exemptions listed in Annex III as of July 21, 2011, unless a shorter period is specified, the maximum validity period, which can be updated, shall be:


a) For categories 1-7 and category 10 of Annex I, 5 years starting from July 21, 2011.

b) For categories 8 and 9 of Annex I, 7 years starting from the relevant dates pointed in Article 4(3).

c) For category 11 of Annex I, 5 years starting from July 22, 2019.


Conclusion: Member states have time until June 12, 2019 to implement the new amendments.



Information has been prepared by the GMA Consult Group team.


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