The recast of the EU RoHS Directive (RoHS 2) introduces specific obligations for importers and distributors. Both of these economic actors are expected to fulfill significant roles in ensuring that manufacturers have met their obligations and that only compliant product is sold in Europe.

Importer obligations include:

• place only compliant products on the EU market
• ensure that Manufacturer has
  • carried out conformity assessment procedures,
  • drawn up technical documentation
  • maintained a register of non-conforming products
• ensure the EEE bears required identification marks, CE mark and is accompanied by required documents
• if reason to believe that EEE is not in conformity, shall not place product on the EU market
  • must inform manufacturer and market surveillance authorities
  • corrective action measures, withdrawal or recall as appropriate
• indicate name and contact info
• maintain a register of non-conforming product and inform distributors
• upon request, provide authorities with information and documentation to demonstrate product conformity and cooperate on any actions taken.

Importers and distributors will be the point of first enforcement in many circumstances and need to be prepared. These businesses may need assistance to ensure that the expectation of these obligations are met within their organizations. ECD Compliance (ECD Technology Ltd.) has the skills and expertise to help your organization become compliant to the RoHS 2 obligations and other environmental requirements. Contact us to discuss how we can help. For additional information on RoHS 2 Directive click here.