‘RoHS’ stands for Restriction of the use of certain Hazardous Substances in electrical and electronic equipment (EEE). RoHS first came into existence in 2002, and it aims to keep the restricted substances out of the waste stream, thus protecting the environment. In 2011, the RoHS Directive was reviewed and a re-cast Directive 2011/65/EU came into effect; the re-cast is often referred to as ‘RoHS2’ and is applicable from 2nd July 2013.

For the purpose of this article, the word “equipment” is used to mean a boat itself as an entity. For brand new boats, the boat builder can fit electrical devices that do not comply with RoHS provided the devices are specifically designed and intended for use on the boat. Such devices would normally form a “permanent” part of the boat and thus do not include items such as a handheld VHF, a handheld GPS or an iPad/tablet.

If at some future date, a boat owner wishes to replace the existing radar, pilot etc (examples of fixed equipment on a boat), they can be replaced with an identical product to the original one fitted to the boat when built (= same make, design, fittings, cabling etc) with no problems in terms of legality – even if the product does contain banned substances.

If the owner wishes to replace his original kit with new kit which has any application other than installation on a boat, PROVIDED the new electrical and/or electronic equipment does NOT contain any of the restricted substances above the specified levels, it can be of any make/size/spec etc and will be legal.

Any product that is NOT specifically designed and intended for use on a boat and, does not by itself benefit from an exemption, comes under the RoHS rules. Typical examples are handheld VHFs, handheld GPS, laptops and games devices, iPads and all other tablets, mobile phones.

Products being manufactured today that fall within the scope of RoHS MUST NOT contain any of the banned substances above the permitted levels.  However, there are changes afoot that will or may add to the existing rules so it is a subject that needs to be watched for updates. The National Measurement Office (NMO), the competent market surveillance authority that enforces RoHS in the UK, will be requested formally to ensure that the BMF technical staff and the BMEEA members are supplied with such updates written in plain English as well as being able to supply our members with the title(s) of updated documents and where they may be viewed or downloaded.

Below is shown a broad classification of the types of products that come within the RoHS requirements together with the dates when the different categories are affected.

Product classifications

Transition dates

Typical marine examples

Large Household

All types not excluded by July 23 2019 Washing machines, microwaves and electric cookers

IT and Telecommunications

All digital electronic products

Consumer

TVs, analogue radios

Luminaires

All lights (including navigation lights, torches etc)

Tools

Electric drills, all electric pumps (including bilge pumps) and outboard motors

Monitoring & Control

July 22, 2014 but July 2017 if considered industrial (includes commercial craft such as fishing boats and other professionally used craft) Autopilots, Electronic compasses, Anemometers, Radar & Thermal vision(this means IR based devices)

Everything

July 2019 includes night vision devices that enhance vision, Galley equipment and all electrical and electronic products

For further detailed information, visit the NMO website www.gov.uk/nmo/rohs

The NMO also operates an enquiry service and these should be addressed to the NMO online at www.rohs.bis.gov.uk/enquiry.aspx , by phone on + 44 (0)20 8943 7227. Enquiries can also be sent in writing to:

NMO Enforcement Authority, Stanton Avenue , Teddington, Middlesex , TW11 0JZ