The RoHS and WEEE directives (2011/65/EU and 2012/19/EU) regulate the use of certain substances and the disposal of electrical and electronic equipment (EEE) at their end-of-life.
In general, an EEE is defined as equipment that depends on electric currents or electromagnetic fields with voltages below 1000 VAC and 1500 VDC for proper functioning. Also included, within the same voltage limits, is equipment for generating, transferring and measuring these currents and fields.
Sometimes, these Directives are also wrongly applied to equipment that should be excluded. Some cases, in fact, lend themselves to erroneous or out-of-context interpretations; specifically, Directive 2011/65/EU in Article 2(4)(c), (d) and (e) refers to:
- equipment which is specifically designed and to be installed as part of another piece of equipment that is excluded from or outside the scope of this Directive and which can only perform its function as part of that equipment and can only be replaced by the same specifically designed equipment;
- to large-scale stationary industrial tools;
- to large-scale stationary industrial installations
These points are clarified in the FAQs of Directive 2011/65/EU under Q3.1.
Wanting to draw a guideline from this document (which is not exhaustive and in any case needs to be studied in more detail for each specific case), it can be deduced that industrial machines can be excluded from the scope of the WEEE and RoHS directives (unless they are small machines that can also be intended for a ‘domestic’ audience), since they require a dedicated disposal system.
The purpose of large, stationary industrial tools and installations is for an informed and technically prepared public to manage the dismantling and disposal of these installations. In some specific cases, it is the manufacturer himself who takes charge of these operations.
What about manufacturers that fall under the applicability of the RoHS and WEEE directives? Article 16 of Directive 2012/19/EU defines their obligations: a manufacturer who produces and places on the market an EEE is obliged to register with the appropriate body in each Member State in which it sells the EEE, as well as to notify the quantities of products sold within each national market. All this in order to allow the Member State to dimension the EEE disposal process.
The list of entities with which to register can be found here.
