Can a “non-RoHS compliant” spare part be used in a “RoHS compliant” system put on the market in the EU after 1 July 2006 or after one of the new compliance dates?
No, the RoHS Directive ONLY permits the use of “non-compliant” spare parts for the repair of electrical and electronic equipment “Put on the Market” before the new compliance requirements went into effect, in otherwords it can be “Repaired as Produced”. For electrical and electronice equipment “Put on the Market” after the compliance date, they must be repaired with spare parts that meet highest EU RoHS requirements applicable to the products.