EPEE Position Paper – FAQ Document RoHS Recast Directive ...

Consequently, it is vital that the definitions given by the RoHS Recast Directive (Art. 3(5)
RoHS Directive: cables means all cables with a rated voltage of less than 250 volts that serve
as a connection or an extension to connect EEE to the electrical outlet or to connect two or
more EEE to each other) are explained sufficiently clearly in the FAQ Document.
The need for clarification is all the more relevant because cables were not part of the scope
of RoHS I. Following Art. Article 2(2) of RoHS Recast, non-compliant EEE that were outside
the scope of RoHS I but inside the scope of RoHS Recast must be granted full market access
until 22 July 2019.
EPEE suggests to clarify the definitions as follows:
- Cables, in so far as they qualify under the definition given in this Directive, will fall within
its scope from 22 July 2019 onwards.
- Wiring that is contained within or integral to EEE does not meet the definition of "cable"
given in Article 3(5). Instead, such wiring is part of the EEE and must therefore meet the
material restrictions and timescale that apply to the EEE itself.
- For EEE which is out of the scope of the RoHS Recast Directive due to exemption of
article 2(4), wiring that is contained within or integral to such EEE are equally out of the
scope of the directive.
- Examples of EEE qualifying as a cable and thus falling under the Directive from 22 July
2019 onwards are (this is a non-exhaustive list): the supply wire between the
convenience outlet and the EEE and eventually external wire to connect accessories such
as the printer, external hard drive.
Regarding large scale fixed installations, EPEE calls upon the European Commission to maintain
the wordings of the latest draft version of the FAQ document on the RoHS Recast Directive, be it
with a clarification regarding ventilating systems (alignment with Ecodesign ENER LOT 10/ENTR
LOT 6); regarding cables, EPEE stresses the need to clarify the definition of cables, as well as the
rules determining whether or not a cable falls within the scope of the RoHS Recast Directive.
About EPEE:
The European Partnership for Energy and the Environment (EPEE) represents the refrigeration, airconditioning
and heat pump industry in Europe. Founded in the year 2000, EPEE’s membership is
composed of 40 member companies and national associations across Europe realising a turnover of
over 30 billion Euros and employing more than 200,000 people in Europe. For more information,
please visit our website: www.epeeglobal.org