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RoHS Directive is transposed into Estonian legislation through:

  1. Waste Act (general ban, general obligations for manufacturer, importer, distributor and authorised representative);
  2. Regulation of Minister of Environment No. 30, 09.05.2011 (RoHS exemptions) (replaces the Regulation of Government No. 154, 0607.2006).

Product of concern is a product the waste resulting from which causes or may cause health or environmental hazards, environmental nuisances or excessive pollution of environment.

Products of concern are: batteries and accumulators, motor vehicles and their parts, tyres, EEE and their parts and agricultural plastics.

Electrical and electronic equipment is an equipment which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields and designed for use with a voltage rating not exceeding 1 000 volts for alternating current and 1 500 volts for direct current.

Dependent means, with regard to EEE, needing electric currents or electromagnetic fields to fulfil at least one intended function.

Place on the market: Product is placed on the market if that product is made available for a first time in the area of the European Community for the purpose of distribution or putting it into service (made available for the third parties). Putting it into service means an activity which involves the use of product for the first time for its intended purpose. For example if product is brought from some Member State then that product is already placed on the market, but if that product is brought for example from China or USA then after that when all procedures related with Customs are done (filled declarations etc.) and it is possible to start to sell or use it. If product is just in bonded warehouse then that product is not placed on the market yet.


Obligations of manufcturer are provided by section 2610 of Waste Act.
Obligations of authorised representative are provided by section 2611 of Waste Act.
Obligations of importer are provided by section 2612 of Waste Act.
Obligations of distributor are provided by section 2613 of Waste Act.



It is prohibited to place to the market EEE or their parts containing the following substances:

  1. more than 0,1 per cent mercury or its compounds by weight;
  2. more than 0,01 per cent cadmium or its compounds by weight;
  3. more than 0,1 per cent lead or its compounds by weight;
  4. more than 0,1 per cent hexavalent chromium compounds by weight;
  5. more than 0,1 per cent poly-brominated biphenyls (PBB) by weight;
  6. more than 0,1 per cent poly-brominated diphenyl ethers (PBDE) by weight.

The prohibition applies to EEE which belong to categories 1, 2, 3, 4, 5, 6, 7 and 10.

All exemptions are provided in Regulation of Minister of Environment No. 30, 09.05.2011.
Guidance for CE-marking and scope you can find from here.






Last updated: 22 March 2018

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