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New RoHS Requirements for Industrial Instrumentation

The RoHS Directive covers the CE Marking requirements on the restriction of use of certain hazardous substances in electrical and electronic equipment (EEE). This Directive has been around for several years and is well known throughout the electronics industry, however companies are often unaware that the scope of the RoHS Directive has been slowly expanding.

The current Directive (2011/65/EU) came into force on the 2nd January 2013, but only applied to categories 1 to 7 and 10. The other categories were then scheduled to be phased in over time to give manufacturers the opportunity to bring their house into order. Categories covering medical devices and monitoring & control instruments came into force in 2014 and 2016, and the next category due to be become applicable in 2017 will cover industrial monitoring and control instruments. After this, there is one final category (cat. 11), covering any other EEE that will apply from the 22nd July 2019.

The distribution chain within the EU must be clear of non-compliant products by 22 July 2019.

This latest category will require all industrial monitoring and control instruments to be RoHS compliant by 22nd July 2017 unless there is an exemption that could be applied. There are number of exclusions that could be applied, but there is one exclusion that stands out:

“(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” (Article 2, paragraph 4 of 2011/65/EU).

For example, if you are manufacturing industrial monitoring and control instrumentation specifically for use on a large-scale fixed installation (one of the exclusions), then the instruments will be excluded from the RoHS Directive.

If this new category is applicable to you then make sure you don’t leave it too late to comply, as the guidance makes it clear that the supply chain must be clear before the 22nd July 2017 deadline.

If you need assistance with CE Marking under the RoHS Directive, then please get in contact.

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