On 3 December 2015, the European Commission published an outline of plans to amend the scope of the RoHS Directive (restriction of the use of certain hazardous substances in electrical and electronic equipment, 2011/65/EU). The legislative proposal was foreseen to be adopted in 2nd quarter 2016.

The intended amendment targets at a serious of problems arising from the RoHS recast of 2011 as follows:

1. Pipe organs problem: Pipe organs have a minor (however integral) electrical function fall under the EEE definition and thus under the RoHS scope. This also affects the non-electric parts of these products, as RoHS restrictions apply to the whole product, i.e. to both electrical and mechanical parts. However, lead alloy required for organ pipes are at risk of violating against the lead limit of RoHS Directive.

2. Secondary market problem: According to the current wording of Article 2(2) in conjunction with Article 4, non-compliant products that have been placed on the market between January 2013 and July 2019, have to be put off the market and cannot be resold or refurbished after 22 July 2019 (no secondary market operations would be possible). It affects all products newly in scope, including non-compliant medical devices and monitoring and control instruments.

3. Spare parts problem: The repair, reuse and refurnished spares for all products (except to medical devices and monitoring and control instruments) shall fulfil the latest restrictions according to RoHS 2.0. This means that products falling within this category, placed on the market lawfully before 22 July 2019, cannot be repaired with spare parts after that date. This means that products falling within this category, placed on the market lawfully before 22 July 2019, cannot be repaired with spare parts after that date.

The European Commission intends to finalise the inception impact assessment by referring to researches in the years 2012-2014 and making preliminary analysis in the three fields.

The Chinese Ministry of Industry and Information Technology (MIIT) published the Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products (also known as China RoHS) last week. It will apply on 1 July 2016 expanding its scope to all electrical and electronic equipment. For your information, RoHS Directive has the most far-reaching impact on electrical and electronic equipment, affecting the entire production chain. C&K Testing advises companies to direct close attention to related news and learn about any amendment.