Does the EU RoHS directive apply to spare parts installed in used equipment?
Maybe, the Directive does not apply to spare parts for the repair, or reuse, of electrical and electronic equipment put on the market before 1 July 2006 (Article 2(3)). This is to insure that older electrical equipment can be maintained and reused. If the product was put on the market after 1 July 06, then RoHS would apply to spare parts for that product.