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September 16, 2014
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RoHS exemption for agricultural equipment in Europe

As an automotive company, we make products that ship to Europe. Automotive is RoHS exempt at present - but we are working toward approvals. We have old product for electronic turn signals that is Agriculture directed and used on tractors. Germany wants to know if this is RoHS compliant. I can't find an answer on agriculture equipment if it has to meet lead-free in Europe. Does anyone know the ruling on this?

T.D.

Experts Comments

While the Automotive industry does fall outside the scope of the RoHS-Directive, the ELV (End of Life Vehicle) 2000/53/EC Directive does cover automotive industry and its products. And yes, much of the ELV has been carried over to the RoHS-Directive.

To see the ELV Directive, visit the EU Website or download the Directive.

On a side note, I would not call the automotive industry "RoHS-Exempt", rather; the Automotive industry has its own ELV directive. In many cases is similar to the RoHS-Directive. Also be aware that the ELV Directive was published in February 2000, three years before the RoHS- and WEEE-Directives.

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Arnold Offner
Industry Standard Manager
Phoenix Contact
With over 15 years service at Phoenix Contact, Mr. Offner has worked in South Africa and Germany. He speaks both English and German, is based in Harrisburg, Pennsylvania and is responsible for the RoHS/WEEE Training activities in the Americas.

EU RoHS does not apply to electrical and electronic products specifically intended for vehicles. The FAQ, recently updated, non-binding, and available at http://ec.europa.eu/environment/waste/pdf/faq_weee.pdf, states "if devices are not specifically designed to be used in vehicles, those devices would be covered by the RoHS Directive. If the devices are designed primarily for use in vehicles (such as car radios) then the ELV Directive applies."

ELV, the End of Life Vehicles directive does apply, but only to certain classes of vehicles. If "Germany" wants to know, I would hope it is not the German government you are referring to. One would hope they understand their own laws.

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Michael Kirschner
President
Design Chain Associates, LLC
Mr. Kirschner is President of Design Chain Associates, LLC, focused on helping electronics OEMs comply with RoHS/WEEE requirements, and speeding time-to-market, reducing product cost, and increasing engineering and procurement efficiency.

Automotive/transportation is not one of the 10 categories under the RoHS Directive. A more appropriate place to look for material issues might be the end of life (ELV) directive.

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Dr. Craig D. Hillman
CEO & Managing Partner
DfR Solutions
Dr. Hillman's specialties include best practices in Design for Reliability, strategies for transitioning to Pb-free, supplier qualification, passive component technology and printed board failure mechanisms.
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