In July 2019 RoHS Directive 2011/65/EU will come into force for construction products with electrical devices. Even it is not written in the directive that the complete window or door with electrical device will become an electrical equipment, construction products shall belong to category 11 (“Other EEE not covered by any of the categories”) as the EU Commission states in the FAQ.
EuroWindoor detected some problems by implementing the RoHS requirements because of different procedures and responsibilities of installing electrical devices to windows and doors resulting in different requirements for the products. Only if the electrical devices are included before the complete product is placed on the market, the RoHS requirements do apply to the complete construction product. More often the electrical devices are installed after the construction product is placed on the marked. Then the window or door complies with CPR / REACH and the electrical devices with RoHS.
In the position paper EuroWindoor explains the different RoHS requirements for windows and doors with electrical devives depending from route of distribution with a motor lock for a door as example.
EuroWindoor suggests to limit the scope to the electrical device of the window/door, something that could be done by clarifying the definition of large scale fixed installations. Windows and doors are normally assembled and installed by professionals and will stay in the building for 40+ years whereas an electrical device itself typically will be replaced 2 to 3 times during this period.
EuroWindoor position on RoHS II for windows and doors with electrical equipment depending from route of distribution (January 2019)
[Here you find all position papers and publications]