Compliance Alert: EAEU RoHS Draft Proposed Amendment

EAEU: Draft Decision for approving Technical Regulations on Restriction of Hazardous Substances in Electrical and Electronic Equipment, Decision No. 113, 2016. The Proposed Amendment is about addition of restricted chemicals, marking and requirements for e-waste, revised scope, etc.

EAEU members include Armenia, Belarus, Kazakhstan, Kyrgyzstan, and Russia. Electric and electronic equipment sold in the EAEU must comply with the EAEU Technical Regulation on the Restriction of the Use of Hazardous Substances in Electrical and Radio-Electronic Products.

In the EAEU technical regulation, six RoHS substances are prohibited, such as:

• Lead
• Cadmium
• Mercury
• Hexavalent chromium
• Polybrominated biphenyls and
• Polybrominated diphenyl ethers

This draft has been amended to include: New added substances. The following substances are proposed to be included in Annex 2 of Technical Regulation No.113:

• Diethylhexyl phthalate
• Butyl benzyl phthalate
• Dibutyl phthalate
• Diisobutyl phthalate

New requirements by EAEU RoHS on responsibility and disposal

The draft proposed to feature new requirements on disposal of electric and electronic equipment and also on the responsibility of extended producers.

• Concerning the requirements of the restriction of use of hazardous substances: processes of disposal of electrical and electronic equipment, a new requirement to Section IV shall be administrated in conformity with the necessities of the national legislation of the Member States of the Union, like the necessities defined in proposed Annex 4.
• Changes are proposed in Marking requirements and following documentation requirements should even be supplemented as: a separate waste collection marking, as provided in proposed Annex 5, should be affixed thereto product, and mentioned in its accompanying documentation.
• Accompanying documentation should have the extra following information:
  • Indication for not disposing e-waste along with unsorted solid household waste. Electronic waste should be collected separately from other waste
  • Hazardous substance information and its possible harmful effects on human health and the environment should be mentioned in the products, if it contains hazardous substances
  • There should be a separate waste collection marking
  • There should be an information “Hand over for recycling if not using. This will prevent damage to the environment”

Scope expansion: The draft proposes to a brand new “open scope” category of products. This adds a brand-new entry 13 to the lists of products in Annex 1, which include: “Other electrical and electronic products not specifically mentioned in Article 3. Electrical and electronic components listed in items 1-12 of Annex 1”.

The deadline for comments is 20 January 2022.