United Arab Emirates RoHS

On April 28. 2017, the United Arab Emirates (UAE) version of RoHS took effect. The UAE version of RoHS is based upon EU RoHS and also adopts a very rigorous timeline with data submissions due to Emirates Authority for Standardisation and Metrology (ESMA) as early as January 1, 2018, depending on product category.

To declare under the UAE Directive, “Form A” is stipulated as the template for the UAE RoHS COC. “Form A” does not exist under UAE RoHS, but rather is an indication of “Module A” from 768/2008/EC, a product marketing decision by the European Commission. A description of “Module A” may be found here, beginning on page 17:
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:218:0082:0128:en:PDF

ESMA, the agency tasked with collection and enforcement of UAE RoHS, is using a certification system (ECAS) by which companies would register products and issue a declaration of conformity. In return, any company (or its authorized representative) making a declaration would receive a “conformity acknowledgement” to retain for 10 years. To use ECAS, a company would register and then issue the declarations via the system. However, at the time of this article, there is no current way to use the system to declare UAE RoHS. There are fees associated with ESMA registration and product/DOC evaluation. Please see the ESMA site here: http://www.esma.gov.ae/en-us/Services/Pages/ECAS.aspx

Additionally, the UAE’s version of the RoHS directive calls for annual renewal of the DOC.

The current consensus is that any existing (acceptable) EU RoHS DOC is going to be acceptable for UAE RoHS. This is due to the harmonization between UAE and EU RoHS. However, this harmonization has its own issues as UAE is not a member state of the EU, likely would never be a member state of the EU, and is relying upon a foreign directive that has grown and changed in scope, exemptions, details, and substances. Hence, there may be issues that confront UAE RoHS in the future.

Finally, any additional questions regarding ECAS registration, product declaration, and UAE RoHS may be directed to customercare@esma.gov.ae, the contact for ESMA.

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