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More EU Regulations - WEEE and RoHS

Advance Notice!

These two regulations potentially affect the use sound modules and electronic elements in greeting cards (eg anything battery powered).

These both look to protect the environment by reducing the growing amount of hazardous waste from toxic and heavy metal substances in electrical and electronic products. Companies are obligated to pay for the recycling and final disposal of their products.


WEEE: Waste Electronic and Electrical Elements – recycling side
RoHS: Restriction of Hazardous Substances

Short version

Advance notice! Greeting card publishers will be responsible for ensuring that any of their products which incorporate electronic components must meet the substance restriction requirements of the RoHS Directive from 2019.

The good news is that we are pretty sure that publishers will still not be obligated for paying for the recycling and final disposal of these modules at end of life through the updated WEEE Directive.

Anther piece of good news is that all modules can be compliant with RoHS – you just need to let your supplier know at the point of order and ensure that you receive the necessary test certifications to validate this by 2019.

Longer version

The WEEE Directive is restricted (by EC supporting guidance) to equipment that is dependent on electric current or electromagnetic fields to perform its primary function. So a greeting card with an electronic element is considered out of scope, as the card could still fulfill its primary function  (that is, as a greetings card) without the electronics. The Department for Business, Innovation and Skills expects this interpretation to continue from 2014, but is still awaiting a new FAQ document from the Commission to replace the current edition. This should be published sometime in the first half of next year and I will let you know if there are any changes.

However, this ‘primary function’ restricted definition of EEE has been removed from the recently revised Restriction of Hazardous Substances in electrical and electronic equipment (or RoHS) Directive – (Directive 2011/65/EU) and now covers equipment reliant on electric currents or electromagnetic fields for any intended function. This means that any greeting cards that have electronic components will come into scope of the new RoHS Directive when it moves to an 'open scope' on 22 July 2019.


For WEEE regs, the advice at the moment is that we think we’re ok from 2014, but are waiting to hear from BIS of any changes. For the RoHS regs, publishers need to make sure that by 2019 they have moved over to the types of modules that are compliant.