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 is a Spanish of counsel in the Brussels office of Covington & Burling.  His practice focuses on EU environmental law, renewable energies, and international trade law.  He advises clients on legal issues concerning environmental product regulation, emissions trading, renewable energies…

Cándido García Molyneux is a Spanish of counsel in the Brussels office of Covington & Burling.  His practice focuses on EU environmental law, renewable energies, and international trade law.  He advises clients on legal issues concerning environmental product regulation, emissions trading, renewable energies, energy efficiency, shale gas, chemical law, product safety, waste management, and international trade law and non-tariff trade barriers.  Mr. García Molyneux was very much involved in the legislative process that led to the revision and amendment of the ETS Directive and Renewable Energies Directive.  He is an external professor of environmental law and policy at the College of Europe.