On RoHS development boards!

This is a contribution by Farnell's Gary Nevison

UK: The status of development kits and evaluation boards under the RoHS Directive has always been unclear and hotly debated within the electronics industry with, as yet, no legally binding decisions being made.

The German government decided many years ago that printed circuit boards sold separately to users to, for example, increase computer memory or add new functions to PCs would be regarded as separate products within the scope of the RoHS and WEEE directives even though these do not have their own enclosures or an individual power supply.

All other States in the European Union (EU) are now of the same opinion. The RoHS directive’s scope is electrical and electronic equipment that is in categories 1-7 and 10 of the WEEE directive. There is no requirement for products to have their own enclosures and they can use any power source including batteries, USB cables etc.

The RoHS directive does not limit its scope except that the product should depend on electricity to function and so clearly single PCBs sold, loaned or given separately to users will be in scope if their main functions are one of the eight RoHS categories.

The only published guidance on development kits and evaluation boards is available from the UK RoHS enforcement body NMO. This states:

Semiconductor evaluation boards
The term Evaluation boards covers a broad range of products from some fairly simple products to fully integrated complex systems. In most cases an evaluation board is effectively a single board computer allowing connection of peripherals and/or input devices to facilitate the programming and testing of chips.

Therefore, most evaluation boards are included under Category 3 IT Equipment of the WEEE directive and must therefore comply with RoHS. On rare occasions these boards may be considered consumables and fall outside the scope of RoHS as described in the commission FAQ

This implies that most types of evaluation board are effectively single board computers and so are in category 3 of the WEEE directive. This is correct for any product whose main function is IT and these will be in scope of the RoHS directive.

It is therefore clear that any development boards that are intended to be used to program ICs will be in scope. NMO admit that some evaluation boards will not be in category 3 although they only mention consumables as examples of those that will be outside scope.

Although most evaluation boards provide information as their main function and so are in scope of RoHS, there will be some exceptions. Category 3 is specifically “information technology and telecommunications equipment” and so not simply the provision of “information” such as the time that would be obtained by an electrically powered clock (regarded as category 4) or a measurement instrument (that might provide information on temperature etc.), which would be in category 9 and so currently excluded from RoHS.

Evaluation boards are available for example for designing lithium battery charger circuits. These have no IT function (so not category 3) and are not intended to charge lithium batteries (so not category 6 – tools). In fact there does not appear to be any WEEE categories that are appropriate for this type of evaluation board.

Conclusion
In conclusion therefore, most single PCBs supplied as evaluation boards will be in scope of RoHS, especially if they have an IT function as most types do. There will be some exceptions however and so it is necessary to review the main functions of each type of board on a case by case basis to determine whether they need to comply with RoHS.

Where there is any doubt, only the courts can give a legally binding opinion and so in most cases it will be better to comply. It is illegal to place non-compliant in-scope evaluation boards and development kits on the EU market. If the producer does not know whether the product is in–scope but knows that it does not comply and the authorities investigate, they would take action if they believe that they are in-scope.

With thanks to Dr. Paul Goodman of ERA Technology, trading as Cobham Technical Services