RoHS and WEEE compliance

RoHS and WEEE deal with different parts of an electrical product’s life. RoHS restricts hazardous substances when equipment is placed on the market. WEEE sets producer and distributor responsibilities for electrical equipment when it becomes waste. The cells in a battery system also sit under separate waste-battery rules.

As at 22 July 2026, the main legislation is the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012 and the Waste Electrical and Electronic Equipment Regulations 2013, both as amended. RoHS operates differently in Great Britain and Northern Ireland. The WEEE regulations apply across the UK, with different environmental regulators administering parts of the system.

These regimes are important, but neither tells you that equipment is suitable for a particular home, eligible for MCS, accepted by the DNO or covered by a good warranty.

Which equipment is covered

Inverters, EV chargepoints, controls and other finished electrical products will normally be electrical and electronic equipment if they depend on electricity or electromagnetic fields for their basic function. The exact product and any statutory exclusion still have to be checked rather than treating every item in an energy installation as identical.

Solar panels have a deliberately different position under the two regimes:

• PV panels produced for permanent use at specific locations are exempt from RoHS
• all PV panels are electrical and electronic equipment for WEEE reporting and have their own WEEE category
• the RoHS exemption for the panel does not automatically extend to its inverter, optimiser, monitoring gateway or other separate equipment

The Environment Agency’s current WEEE scope guidance treats all PV panels as household equipment for reporting purposes, including panels installed on commercial premises or solar farms. It does not treat a solar farm as a large-scale fixed-installation exclusion for the panels themselves.

A battery product needs two questions. Its electrical enclosure, controls and power electronics may be EEE, while the battery weight is reported separately under the waste-battery regime. A finished battery system should not simply be described as either “WEEE” or “not WEEE” without separating those parts.

What RoHS compliance means

RoHS controls ten substances in each homogeneous material, not as an average across the whole product. Under the rules current at this review date, cadmium is limited to 0.01% and the other nine substances are limited to 0.1%:

• lead, mercury and hexavalent chromium
• polybrominated biphenyls and polybrominated diphenyl ethers
• DEHP, BBP, DBP and DIBP phthalates

The regulations also contain exemptions for particular technical applications. Great Britain operates its own exemption system, while Northern Ireland follows the EU system. A claim based on an exemption therefore needs the exemption reference and the destination market, not just the words “RoHS compliant”.

For equipment in scope, the manufacturer must hold technical documentation, complete a declaration of conformity and provide the required product identification and conformity marking. The RoHS technical package includes the declaration, conformity-assessment record and supporting production-control evidence such as test reports. It is retained for ten years after the last product is first placed on the market and made available to the regulator on request.

That does not mean a householder will receive the complete technical file. The useful handover document is the declaration of conformity for the exact model and revision. Its product identity should match the rating plate, manual and installed unit.

Great Britain currently recognises CE marking for RoHS equipment as well as the UKCA route. Northern Ireland uses CE, or CE with UKNI where a UK body is involved in a required third-party assessment. Marking rules are explained separately in the UKCA and CE entry.

Importer, producer and take-back responsibilities

For an inverter, EV charger, heat-pump control or battery power-conversion unit, keep:

• a photograph of the rating plate and conformity mark
• the exact model, hardware revision and serial number
• the declaration of conformity used for the destination market
• the manufacturer’s and UK importer’s identities, where applicable
• the supplier’s written WEEE take-back information
• the battery producer’s return information where the product contains an industrial battery

A conformity symbol on its own is not enough to identify the applicable legislation or the product covered by the declaration. It is also not proof that every material was independently laboratory tested, because the permitted conformity route can include manufacturer self-declaration.

Direct imports need extra care. A private individual importing equipment is not made a WEEE producer by the regulations, but that does not create a convenient UK take-back or support route. The supply chain needs an identified party responsible for UK import, product compliance and end-of-life treatment.

What WEEE changes for the owner

Electrical equipment within scope carries the crossed-out wheeled-bin symbol. It must be kept out of ordinary household rubbish and passed into an appropriate reuse or recycling route.

Producers register and finance the collection, treatment and environmentally sound disposal system. Distributors, including retailers, must tell customers which take-back service they provide. When they supply a new household electrical product, they must provide a free route for an old item of the same type or function, regardless of brand or whether the new item was bought in a shop or online.

“Free take-back” does not always mean free collection from the home. Current government guidance allows a retailer to charge its transport costs when collecting from a customer’s property. It must allow at least 28 days for an item to be returned to an in-store service. For installed equipment, agree removal, safe isolation, packaging, collection and any transport charge in writing before replacement work starts.

Producer financing and distributor take-back are also different duties. WEEE does not give every householder an unconditional right to demand free collection from any manufacturer, nor does it show that the disposal cost of every panel installed since a particular year has already been paid in full.

Replacing or disposing of solar equipment

Do not put panels, inverters, optimisers or monitoring equipment in general waste. When replacing them:

1. Ask the seller of the replacement equipment for its written like-for-like take-back route.
2. Make the installer state who will own the removed equipment and where it will go.
3. Separate reusable equipment from waste. A working panel can be reused only if it remains a product rather than being discarded as waste, and its condition and electrical safety still need assessment.
4. If using a household waste recycling centre, confirm in advance that it accepts that item and quantity. Acceptance of large panels and installed equipment varies by site.
5. Keep the collection or transfer paperwork with the installation records.

The old installer going out of business does not make the equipment ordinary rubbish. Start with the replacement retailer, the manufacturer’s published return route, the relevant producer-compliance scheme or the local authority’s confirmed electrical-waste service.

Batteries use a separate return route

Waste batteries are governed separately from the WEEE weight of the surrounding equipment. The rules divide them into portable, automotive and industrial batteries. A sealed battery that is not portable falls within the industrial definition, so a fixed or heavy home-storage battery will normally need an industrial-battery route. Confirm the classification for the exact product.

Industrial-battery producers must publish how end users can return batteries and must take them back free in the circumstances set by the regulations. Those circumstances include supplying a new battery, accepting the same chemistry as batteries the producer places on the market, or cases where the battery cannot be returned to another producer. Treatment and recycling must go through an approved battery operator or exporter.

Do not use a supermarket portable-battery box for a home-storage module. Do not put a lithium battery into general waste, and seek specialist advice before handling a battery that is damaged, swollen, leaking, wet or unusually hot.

What these rules do not prove

RoHS, WEEE registration or a take-back arrangement does not establish that equipment:

• meets electrical or fire-safety requirements
• has the right G98 or G99 type-test evidence
• is on an MCS certified-product list
• is compatible with the rest of the system
• has a valid product or workmanship warranty
• will be removed from the property without a transport or labour charge
• will be recycled at a particular recovery percentage

Treat product conformity, installation quality, warranty support and end-of-life arrangements as separate checks.

Related entries

• UKCA and CE marking transition
• Battery end-of-life recycling
• BS EN 62109 inverter safety standard
• PAS 63100 domestic battery fire specification
• MCS
• PV commissioning pack