> From: Ron Pickard [mailto:[email protected]]
> Sent: Thursday, September 06, 2012 09:30
>
> Brian,
> Further to Mark's reply, please note that compliance to
> the recast RoHS Directive is to be indicated in a
> product's DofC (Article 13) and CE marking (Article
> 16).
>
> IMHO, a CE marked product itself must adhere to the
> requirements of any EU directives that are applicable
> to it including the recast RoHS Directive.

It's also important to note that the former RoHS Dir. only applied to
those products covered by the WEEE Dir.  The RoHS recast removed this
limitation of applicability.

However, in Article 2,

"2. Without prejudice to Article 4(3) and 4(4), Member States shall
provide that EEE that was outside the scope of Directive 2002/95/EC, but
which would not comply with this Directive, may nevertheless continue to
be made available on the market until 22 July 2019."

So products are not, strictly speaking, required to comply with the RoHS
recast now, if they were out of scope previously.  These products are
allowed to apply the CE mark until mid 2019.


Regards,

Peter Tarver


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