Is generating equipment such as petrol or diesel generators within the scope of RoHS?
Yes, as the RoHS Regulations apply to EEE which is dependent on electric currents or electromagnetic fields in order to work properly, including equipment for the generation, transfer and measurement of such currents and fields. These products can be considered to be within scope under Article 2.1. They fall into Category 6 as a tool. The RoHS Directive does not have a general size exclusion. If it is reasonable to consider a small generator as a tool because of its general nature to ‘generate’ or do work then it is reasonable to apply to larger generators up to and including power stations. This has been considered at the EU level, the view gained is that generators up to a single wind turbine is in scope but wind farms and national grid power stations are excluded as large scale industrial tools (LSIT).
Related Questions
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