Electronic devices and their components marketed in the European Union and European Economic Area are subject to a morass of environmental and product safety requirements that is only likely to increase with the EU’s implementation of its Circular Economy Strategy in the near future.  The requirements apply to all types of equipment, from sophisticated information technology equipment, to military equipment, aircraft components, electronic medical devices, household electronics, consumer devices, and industrial tools.

The requirements affect the products’ environmental design and recyclability, energy efficiency, chemical composition, electromagnetic compatibility, radio frequency and electrical safety, labelling, and disclosure and waste take back obligations.  They affect the electronic devices and components, as well as their batteries and packaging.

In effect, the requirements are imposed by a variety of legislation that often overlaps, such as the Directive on Waste Electrical and Electronic Equipment (“WEEE Directive”), the Directive on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment (“RoHS Directive”), the Directive on Energy Related Products, different Regulations on Energy Efficiency Labelling, the Directive on Batteries and Accumulators and Waste Batteries and Accumulators, the Directive on Packaging and Packaging Waste, the Directive on Electromagnetic Compatibility, the Low Voltage Directive, the Radio Equipment Directive, the Regulation the Registration, Evaluation, Authorization and Restrictions of Chemicals (“REACH Regulation”), the Regulation on the Classification, Labelling and Packaging of Mixtures and Substances (“CLP Regulation”), the Biocidal Products Regulation, and the Fluorinated Gases Regulation.  In addition, electronic devices marketed in the EU/EEA are subject to the General Product Safety Directive, and to specific product safety standards adopted under that Directive.

The following table provides an illustrative and non-exhaustive check list of the different requirements that apply to electronic devices and their components, batteries and packaging when marketed in the EU/EEA.

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Photo of Cándido García Molyneux Cándido García Molyneux

Cándido García Molyneux provides clients with regulatory, policy and strategic advice on EU environmental and product safety legislation. He helps clients influence EU legislation and guidance and comply with requirements in an efficient manner, representing them before the EU Courts and institutions.

Cándido…

Cándido García Molyneux provides clients with regulatory, policy and strategic advice on EU environmental and product safety legislation. He helps clients influence EU legislation and guidance and comply with requirements in an efficient manner, representing them before the EU Courts and institutions.

Cándido co-chairs the firm’s Environmental Practice Group.

Cándido has a deep knowledge of EU requirements on chemicals, circular economy and waste management, climate change, energy efficiency, renewable energies as well as their interrelationship with specific product categories and industries, such as electronics, cosmetics, healthcare products, and more general consumer products.

In addition, Cándido has particular expertise on EU institutional and trade law, and the import of food products into the EU. Cándido also regularly advises clients on Spanish food and drug law.

Cándido is described by Chambers Europe as being “creative and frighteningly smart.” His clients note that “he has a very measured, considered, deliberative manner,” and that “he has superb analytical and writing skills.”