|Ask the Experts|
February 5, 2019
RoHS existing products vs. new products
Regarding RoHS; if we have been building product XYZ for 2 years now and will continue building it for sometime, will it have to be converted to lead free after July 1, 2006? It is my understanding that only NEW products, not product currently in production, will need to be RoHS compliant after July 1, 2006, am I correct?
|Expert Panel Responses|
To my knowledge, all products not specifically given and exemption by the EU must be lead free.
North America Sales Manager
Nope. New in the RoHS Directive as in "from 1 July 2006, new electrical and electronic equipment put on the market does not contain lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE)," means newly manufactured, not newly designed. Another way to view it is that Dell can not sell a lead-containing computer in Europe after July 1, but a private transaction of a used Dell computer containing lead is still allowable. Reference: http://www.dfrsolutions.com/Information/RoHS%20Directive.pdf
CEO & Managing Partner
You have misunderstood the word "new". All products sold into the EU must be lead free with certain exceptions. Just because it is not a "newly" developed product does not make it exempt. In this document "new" means not "used".
Regional Sales Manager
OK International Inc.
There are folks far more knowledgeable than I on the RoHS Regulations, however I think you are incorrect. The way I understand the regulations is that ANY product offered for sale in EEU nations that is not clearly exempt from the regulation must comply by July 1, 2006. This means the product that you are offering for sale on July 1, 2006 must comply not that you start producing products that comply on July 1, 2006. I also find that for some reason many customers I visit think they are exempt from the RoHS Regulations. There are only a few exemptions so if you think you are exempt you should verify if you are by working with an industry expert/consultant.
Products that will be sold in the EU as of July 1, 2006 need to be compliant with the RoHS legislation. For example, if you are building product XYZ and sell it in the EU in June it can contain lead, antimony, poly-bominated biphenyls, etc. That same product sold a month later must meet the criteria set forth in the EU legislation. Therefore it is not defined by if the design is new, but when the physical device is sold in the region under the jurisdiction. In addition, China has legislation that is being finalized that is a copy of the EU RoHS legislation. Furthermore, it should be recognized that California may be enacting similar legislation (an exact copy of the EU RoHS legislation).
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