The revised RoHS now applies to all electrical and electronic equipment (EEE). Medical Devices and Monitoring and Control Instruments shall be category 8 and 9 respectively and will come into scope by 2014.
The additional category 11 now will cover all EEE not covered by any other category. It will come into scope by 2019. This catch-all will bring devices such as electromechanical into scope.
In the past, EU government had to prove particular products should not have exemption status. That has been reversed with the recast. Now, industry has to prove it needs an exemption (such as the device cannot be produced effectively without RoHS-banned substances). Plus, all exemptions will have expiration dates.
To avoid the expiration date, companies will need to submit renewal applications at least 18 months before the exemption expires. “Design engineers will need to know what is in the product and when any exempted material will expire. There are 32 exemptions and some have multiple parts, a, b or c. They have different dates when the exemption will expire”.
The CE Marking Directive that requires Mfrs, Distis and importers to accurately label EEE products sold into the EU is now part of RoHS. It also includes technical documentation. In the past there was no documentation requirement. However, there are questions about where to put the CE Mark.