Selling non RoHS equipment?

[peps1]

Hello guys,

Trying to learn about EU directive that effect electronics, and was wondering if someone could explain this one to me:

RoHS Non Compliant Part
https://www.rapidonline.com/silonex-light-dependent-resistor-norps12-58-0132

RoHS Compliant product using that part
https://www.rapidonline.com/rapid-ldr-pcb-project-kit-70867

What exemption is allowing this to be sold in the EU? 

(Sorry if this should have been posted in another section like general chat, just thought it may fit under the "Technical Stuff" remit)

[Neilm]

There are a couple of things it could be. First thing I notice is it is a kit - there may be something in legislation that says it doesn't apply to descrete items and kits. (I work in a big company and that loophole would't apply to our products - I am by no means an expert)

Alternately, the sensor supplied in the kit is not the one identified but a similar one that is RoHS compliant.

[peps1]

Yes, its an interesting one, and being an own-brand product for Rapid I would be surprised if it was just a mistake/oversight.

I did check to see on the data sheet for the kit, and it has that same Silonex Light Dependent Resistor listed that is non RoHS 

[Matir]

Not authoritative by any means, but this article implies that "kits for self-assembly" are not covered by RoHS: https://www.electronicsweekly.com/blogs/directive-decoder/eu-rohs/kits-and-the-blue-guide-2007-03/

[fcb]

There used to be a RoHS exemption (I think it ended in 2009 or something) for Cadmium in photocells for portable audio gear (vactrols  typicall used in the compressor stage) - a few of the boutique synth companies ignored/ignorant of the law and made/sold products into the EU.

Not sure what the rules are in the US or the rest of the world, but Cadmium vactrols are pretty rare these days.