| What about spare parts? |
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 What about the spare parts for support and warranty work? Are they subject to EU RoHS or China RoHS rules?Spare parts are not products within themselves but sub-assemblies supplied for repair post placing of the product on the market.
For China RoHS, spare parts that can be sold independently are subject to the Chinese RoHS directives, including marking. Read more about China RoHS here
For EU RoHS, spare parts for repair of products placed on the market before 1 July 2006 are exempt from the requirements of RoHS. The EC's 'Guide to the implementation of directives based on the New Approach and the Global Approach' (the 'blue book') describes repairs on page 16 as
and
For example, modifications may have taken place due to technical progress, or discontinued production of the old part. Translation: maintenance operations are basically excluded from the scope of the directives. But, for EU RoHS, if a product first placed on the market before 1 July 2006 is subsequently modified (changing its function, performance or type) by the use of spare parts may be deemed a new product and need to comply. Translation: upgrades to existing products might require RoHS compliance for the old product.
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