RoHS Scope and Exclusions (Article 2)

The scope of EU RoHS Directive 2011/65/EU is defined in Article 2. It applies to EEE falling within the categories of Annex I, cables and spare parts for repair and reuse, and accessories. The open scope (since July 22, 2019) covers all EEE not explicitly excluded. Article 2(4) excludes specific items from RoHS scope, including: equipment for military and security purposes; space equipment; large-scale stationary industrial tools; large-scale fixed installations; means of transport for persons or goods (excluding electric two-wheel vehicles); non-road mobile machinery for professional use; active implantable medical devices; photovoltaic panels; equipment for research and development only.

Directive 2011/65/EU, Articles 2 and 3; Article 2(4) (exclusions).

Before beginning a RoHS compliance assessment, manufacturers must confirm that their product falls within RoHS scope and is not excluded under Article 2(4). Large-scale stationary industrial tools and fixed installations are commonly misunderstood exclusions — they must be truly ‘large-scale’ and ‘stationary’ to qualify. Note that exclusions apply to the entire product — individual components sold separately for excluded uses may still be subject to other EU chemical restrictions (e.g., REACH). Products entering the EU from outside may be excluded even if the same product is regulated in other jurisdictions.