Lead Free Design - RoHS


What does "Placed on the Market" mean?

China RoHS and EU RoHS have very different definitions for "placed on the market".

For EU RoHS, "placed on the market" is defined for the purposes of RoHS in the European Commission's 'Guide to the implementation of directives based on the New Approach and the Global Approach' (commonly referred to as the 'blue book').

China RoHS is very different... 

The general principles of "placing on the market" for EU RoHS are:

  • The product is sold in the EEA
  • The product new and not second hand
  • The product must be transferred out of the manufacturing stage
  • The principles apply to each individual item
  • The principles include free transfer (gifts) and sale for charge
  • The principles apply to products imported into the EEA

RoHS does not apply to:

  • Products manufactured in house for your own internal use
  • Prototypes and samples for demonstration (customer use as "loaner")


For China RoHS,
after the initial deadline for Marking has passed, the definitions are similar.

However, new "Placed on the Market" rules prevent "channel stuffing"; each step in the chain from dock to retail shelf must be compliant on the effective date of March 1, 2007.