In some EU Member States the duty of registration and reporting for producer responsibility has been assessed based on specific product names or product lists. This misinterpretation has now been eliminated in the directive recast. It is explicitly stated that the producer responsibility for EEE is based on a so-called "open scope". In brief, this means that all products and equipment dependent on electrical currents or electromagnetic fields are covered by the rules - with a few exceptions.

As to the product exceptions in the recast it should be noted that the amendments primarily concern clarifications regarding equipment that was already excluded.

Subject to producer responsibility

Generally, all electrical and electronic equipment is covered by producer responsibility (in-scope), and is defined as equipment dependent on electrical currents or electromagnetic fields and/or used for the generation, transfer and measurement of electric currents or electromagnetic fields.


Certain types of EEE excluded from the duty of registration and reporting cf. this directive:

  • Special equipment manufactured specifically for military and security purposes.
  • Specifically designed and installed as part of another type of equipment.
  • Equipment for research and development.
  • Filament bulbs.
  • Equipment designed to be sent into space.
  • Large-scale stationary industrial tools (LSSIT).
  • Large-scale fixed installations (LSFI).
  • Means of Transport for persons or goods (MT ).
  • Non–Road Mobile Machinery (NRMM).
  • Infective medical devices (MD).

Last edited: 20/12/2017
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