Greetings everyone,

Regarding the RoHS recast directive; DIRECTIVE 2011/65/EU OF THE EUROPEAN 
PARLIAMENT AND OF THE COUNCIL of 8 June 2011, on the restriction of the use of 
certain hazardous substances in electrical and electronic equipment (recast) – 
see attached.


Article 2 states:
Scope

4. This Directive does not apply to:



(i)                   photovoltaic panels intended to be used in a system that 
is designed, assembled and installed by professionals for permanent use at a 
defined location to produce energy from solar light for public, commercial, 
industrial and residential applications;


1.                   Does anyone know if this includes micro-inverters?  I 
would assume so as the PV module then becomes an ‘AC PV module’ but maybe not 
….. as there are more RoHS concerning components in a micro-inverter than in a 
DC PV module.


2.                   Does this exemption include combiner boxes? Does the 
exemption include String inverters? Rest of the BOS? I would assume so as it 
also states:

(c) equipment which is specifically designed, and is to be installed, as part 
of another type of equipment that is excluded or does not fall within the scope 
of this Directive, which can fulfil its function only if it is part of that 
equipment, and which can be replaced only by the same specifically designed 
equipment;

Most installations do not have such specific restrictions on the usage of which 
inverters are to be used for DC panels, etc.


The directive does mention the following:
(17) The development of renewable forms of energy is one of the Union’s key 
objectives, and the contribution made by renewable energy sources to 
environmental and climate objectives is crucial. Directive 2009/28/EC of the 
European Parliament and of the Council of 23 April 2009 on the promotion of the 
use of energy from renewable sources ( 4 ) recalls that there should be 
coherence between those objectives and other Union environmental legislation. 
Consequently, this Directive should not prevent the development of renewable 
energy technologies that have no negative impact on health and the environment 
and that are sustainable and economically viable.

Can someone interpret the bold underlined statement above? It leads to a vague 
interpretation me thinks.

Thanks in advance.

Regan Arndt


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