RFID tags (Active RFID tags, and Passive RFID tags) are often used attached to other articles, for example for stock identification or theft control. The RFID tag is in these cases not deemed a part of the article, as it is not intended to function together with the article but rather to be removed prior to shipment or use (for example packaging). In this case, the requirements of RoHS 2 should apply to the RFID only and not to the article to which it is attached, unless the attached article is itself EEE and falls under scope.

Are RFID tags in scope of RoHS regulation?

Yes. RFID tags (active and passive) are in the RoHS scope and should comply with RoHS 2 as they meet the definition of Electrical and Electronic Equipment (EEE) as set out in Article 3(1), unless they benefit from an exclusion in Article 2(4). They are generally considered category 3.

RFID which are attached permanently to (or are difficult to separate from) appliances/equipment falling into other Categories of RoHS, may be considered a component part of such appliances/equipment and thus be considered under the same category as that appliance/equipment.

But RFID Readers and RFID Printers are considered as consumer electronics, so they are also covered in the scope of RoHS regulation.

Does Electrical/Electronics packaging have to comply to RoHS 2?

No. Recital 14 states RoHS is without prejudice to specific waste management legislation therefore packaging pursuant to the Packaging and Packaging Waste Directive (94/62/EC) is outside the scope of RoHS 2.

Any packaging that is discarded after purchase of the product is not considered to be part of the EEE and therefore does not fall within the scope of the RoHS regulations. However, compliance of a case or packaging that forms part of, or may stay with, the product and may be disposed of with the product may need to comply; this must be judged on a case by case basis. Think of a sticker commonly left on the bottom of a laptop, for instance. Or a special piece of packaging attractive to children that a child wants to keep.

Industry intelligence will advise that packaging suppliers and users be sensible: know what’s in your packaging. Declare or be ready to declare anything that remotely smacks of cadmium, lead, mercury or the other three primary suspects in the RoHS case. Remember, suppliers can pass you cadmium in paint — packaging companies and customers must be on top of their ingredients.