Is it okay to CE mark the product until the RoHS2 directive goes into effect?

dr1vn

Involved In Discussions
#1
We are looking to launch a device used to provide very accurate measurements of flat surfaces. It will be sold to industries so the device falls into Category 9 - Industrial Monitoring and Control Instruments in the RoHS2 directive. However, some of the parts on the PCB are not RoHS compliant. While we are working towards getting these parts compliant is it okay to CE mark the product until the RoHS2 directive goes into effect in July 2017?
 
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QAengineer13

Quite Involved in Discussions
#3
Hi dr1Vn,

As you mentioned in your post the ROHS 2 directive applicable to your category is not due into full force until July 2017. So as a business if you want to place the product in the EU market then your CE marking supporting documents should only reference the old ROHS directive and not the Recast ROHS 2 and your DOC should also reference the same.
 

somashekar

Staff member
Super Moderator
#4
Hi dr1Vn,

As you mentioned in your post the ROHS 2 directive applicable to your category is not due into full force until July 2017. So as a business if you want to place the product in the EU market then your CE marking supporting documents should only reference the old ROHS directive and not the Recast ROHS 2 and your DOC should also reference the same.
Based on the OP description, would his product meet the current RoHS directive ?
His product may also be within other directives requiring a CE mark
Its always one CE mark, many directives.
 

dr1vn

Involved In Discussions
#5
Thanks! Yes we meet the Low Voltage and EMC directives. I believe those are the only two that apply in our case...

However, I didn't think about RoHS1... Do we need to be in compliance with RoHS1 for CE marking? I'll need to go back and re-read it (again). :eek:
 

dr1vn

Involved In Discussions
#7
So Article 2 (Scope) of RoHS1 limits the scope to, " electrical and electronic equipment falling under the categories 1, 2, 3, 4, 5, 6, 7 and 10 set out in Annex IA to Directive
No 2002/96/EC".

Our product falls in to Category 9 (Measurement and control equipment) so it looks like RoHS-1 does not apply here as well. So, my conclusion is to go ahead and CE mark for now.

I really appreciate it when people point out other points to consider when making a decision. It makes me more confident on the final decision.
 

CharlieUK

Quite Involved in Discussions
#8
You only CE mark Directives that you fall into the scope of, so if your product is outside the scope of 2011/65/EU (RoHS 2) you do not CE mark to RoHS as 2011/65/EU superceded RoHS 1 which no longer applies and you do not mention RoHS on your DoC.

You are allowed to "place equipment on the market" right up to the deadline, so please check the Blue Guide for clarification on that, http://ec.europa.eu/DocsRoom/documents/18027
 
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