3 Lists of equipment

Impact assessment of introduction of a general scope of the RoHS Directive – selected aspects

Table 3.1 lists the identified product groups which are considered by the authors (using a broad definition of EEE) to fall within the scope of one of the categories listed in Annex I, but not included in Annex II of the Commission’s proposal. There may be many views on where the different product groups fall, and this represent only the view of the authors.

Product groups, for which it is not clear to the authors whether they are already covered by the Commission’s proposal, are marked in grey.

For some product groups links are provided to pictures of products within the group.

Further it is indicated to what extent the product groups are covered by specific CN codes that could be used for estimating the market volumes. It is a minority of the product groups that are covered by specific CN codes and this makes estimation of the total market volume of the listed products on the bases of the trade statistics impossible.

In Denmark, the introduction of the binding list of the Commission’s proposal would imply that at least 27 product groups would change status from being within the scope to being outside the scope. These product groups are marked with a “” in Table 3.1.

Up to 26 product groups, within the scope of the 10 Categories in Annex I, would by the introduction of a general scope and a broad definition of EEE change status from being outside the scope of the Danish RoHS legislation to fall within the scope. These product groups are not marked with a “” in Table 3.1.

In total, 53 product groups were identified that are considered by the authors, to be within the scope of one of the categories listed in Annex I, but not included in Annex II of the Commission’s proposal

For four categories: 3, 4, 5 and 8 the description of the product groups in Anne II is so all-embracing that it has not been possible to identify any products falling within the categories of Annex I which are not covered by the description in Annex II. These product categories represented about 38% of all WEEE arising in 2005 (Huisman et al., 2007). As an example the description “equipment for the purpose of spreading or controlling light” covers any lighting equipment on the market and any that may be developed in the future independent on the purpose of spreading the light.

Table 3.2 includes a list of finished products with EE components considered by the authors neither to fall within the scope of the Annex I categories, nor specifically be designed for military applications, large-scale stationary industrial tools, aerospace applications, transport equipment or “fixed installations”. The products groups are not considered to be within the scope of the existing RoHS Directive and not within the scope of the existing Danish RoHS legislation.

By an introduction of a general scope and a broad definition of EEE these 24 products groups would fall within the scope of the Directive. Some of the product groups like veterinary devices, other laboratory equipment and equipment for generation, transmission or conversion of electricity obviously fall within the current definition of EEE. Other product groups like furniture with EE components or clothing with EE components are in the grey area and may fall outside the scope of the Directive if a more narrow definition of EEE is applied.

Using the “discard test” in fact only a few of the products would not be discarded or not be significantly downgraded if the electrical parts failed and could not be repaired: Clothing and footwear with EE components, cupboards with light, shower heads with light and makeup mirrors with light. These products would probably still be able to serve their main purpose without the EE component.

Some of the other products may still be used, but would be significantly downgraded e.g. elevation tables and beds or ornaments with EE components.

Click here to see: Table 3.1 List of product groups considered by the authors to fall within the categories in Annex I

Click here to see: Table 3.2 List of product groups considered by the authors to fall outside the scope of the categories in Annex I, nor specifically be designed for military applications, transport equipment, aerospace applications, fixed installations or large-scale stationary industrial tools.