I know this is not the RoHS forum, but I am having trouble with a simple
question and hope someone here can point me in the right direction. Have
not been able to get a clear reading from "RoHS" web sites.

We make ITE/AV equipment, category 3 and 4 in RoHS Directive Annex I.

At what date must our product be compliant with RoHS 2.0 ( the added 4
substances restrictions)? I say immediately on publication of the first
country legislation implementing Directive (EU) 2015/863 or 31 December
2016. One of our factories is arguing that the additional 4 substance
restrictions do not apply to our products until 22 July 2019.

Which of us is correct? (If you feel generous, please cite page, paragraph,
rule where you base your comment on.)

Thank you one and all for your comments.

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