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An important change has been made to the Directive 2011/65/EU published on June 8, 2011 for Restriction of Hazardous Substances (RoHS) for electric toys and electrical and electronic equipment (EEE).

Products that had previously been excluded from the directive’s scope should now be compliant, as of July 22, 2019.

Clarity of Definitions

The RoHS II Directive 2011/65/EU, introduced in 2011, added a new definition of “dependent on electric current” as part of the EEE: ‘dependent’ meaning needing electric currents or electromagnetic fields to fulfil at least one intended function’. The directive views EEE as ‘equipment which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields and designed for use with a voltage rating not exceeding 1,000 volts for alternating current and 1,500 volts for direct current’.

The prior RoHS Directive, 2002/95/EC, contained the same definition for EEE equipment but ‘dependent’ was interpreted differently. The FAQ related to RoHS I states that equipment was considered as EEE when it needed electricity for its principal function. However, in RoHS II, electricity is only needed for ‘at least one intended function’ (Art. 3.2) for the equipment to be categorized as EEE.

What about Electric Toys?

Toys have been in scope of RoHS I under category 7 from the beginning with specific examples given in Annex IB. However, with the change in definitions, RoHS II now includes toys with minor/secondary EE functions (meaning they would keep their play value even without the EE function) in the substance restriction requirements as they do have ‘at least one intended function’.

All EEE (including toys with minor/secondary EE functions) placed on the market after July 22, 2019 need to comply with RoHS II requirements.

SGS is committed to providing information about development in regulations for consumer products as complimentary services. With the change in this directive, they recommend stakeholders assess their current status to ensure compliancy. Through a global network of experts, SGS provides a wide range of services including testing and consultancy work for technical and non-technical articles covering a wide-reaching range of consumer products. Please do not hesitate to contact us for further information.

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For more information, please contact:

Sanda Stefanovic
Global Toy Expert

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