For electrical and electronic equipment, two directives with two different mechanics, plus the batteries regulation. RoHS (
Directive 2011/65/EU, Annex II as amended by Delegated
Directive (EU) 2015/863) restricts ten substances: lead, mercury, cadmium, hexavalent chromium, the brominated flame retardants PBB and PBDE, and the four phthalates DEHP, BBP, DBP and DIBP. The limit is not measured on the appliance as a whole but per homogeneous material (Article 4(2)): a solder joint, a cable sheath, a piece of housing, a coating each has to stay under the limit on its own, so a test report on a whole appliance as one sample proves nothing. Cadmium is capped at 0.01 % by weight, the other nine at 0.1 %. The phthalates have applied since 22 July 2019, and since 22 July 2021 for medical devices and monitoring and control instruments; they do not apply to cables or spare parts for equipment placed on the market before those dates. RoHS is proven in the technical file and there is nothing to register, but Article 9 gives the EU importer his own checks, and under Article 11 an importer who sells under his own name or trade mark, or modifies the equipment, is treated as the manufacturer.
WEEE (
Directive 2012/19/EU) is a registration in the national producer register of each member state where the equipment is placed on the market (Article 16); there is no EU-wide register. On goods brought in from Thailand the EU importer is himself the 'producer' under Article 3(1)(f)(iii), so the registration and collection duties are his, not the Thai maker's. An authorised representative under Article 17 does not solve it: that article covers producers established in another EU member state, as a possibility rather than a duty (Article 17(1)), and distance sellers who are themselves established in a member state (Article 17(2)). A producer in a third country falls under neither. WEEE is a directive, so check the national transposition and the national register per member state.
Anything with a cell or a battery pack in it also falls under
Regulation (EU) 2023/1542, whose Chapter VIII has applied since 18 August 2025. Here too the producer is whoever first makes the battery available on a member state's market on a professional basis, normally your EU importer (Article 3(47)(c)). He must be entered in that member state's producer register before he may make them available, including batteries already built into an appliance or a vehicle (Article 55(2)), in each member state where he himself first supplies them rather than in every member state the goods later reach. The take-back and collection duties themselves sit in Article 56 and Articles 59 to 61, not in Article 55, and the competent authority has up to 12 weeks to register him once the file is complete (Article 55(9)(b)). Parts supplied to a vehicle manufacturer follow that manufacturer's type approval instead; parts sold as spares to consumers do not.
Source: Directive 2011/65/EU (RoHS), Article 4(2) (limit per homogeneous material), Article 9 (importers), Article 11 (importer treated as manufacturer) and Annex II, consolidated version of 1 August 2024, with the four phthalates added by Delegated
Directive (EU) 2015/863;
Directive 2012/19/EU (WEEE), Article 3(1)(f), Article 16 and Article 17, consolidated version of 8 April 2024;
Regulation (EU) 2023/1542 (batteries), Article 3(47), Article 55, Article 56, Articles 59 to 61 and Article 96(2)(c) (Chapter VIII applies from 18 August 2025).
EUR-Lex RoHS consolidated ·
EUR-Lex 2015/863 ·
EUR-Lex WEEE consolidated ·
EUR-Lex 2023/1542. See
RoHS and WEEE.
Checked: 5 September 2026.