Warning: LDRs (Light Dependent Resistors) contain cadmium, a hazardous material

ROHS defines electrical and electronic equipment (EEE) as equipment that encompasses finished product ‘for direct use by the end user’ and also product as a 'component' placed on the market for further production or integration into a finished product, as the LDR pre-amp boards come populated and ‘complete’ and are intended to ‘perform an electrical function’ in a finished product they fall within the scope of ROHS. As no distinction is made between DIY or commercial product the above is an umbrella definition.

Important links:

Cadmium and you: Working with cadmium: Are you at risk?

ROHS REGULATIONS: Government Guidance Notes

Significant points:

EU amendment 2012/51/EU provided an exemption to the ROHS2 directive 2011/65/EU allowing the use of LDRs containing cadmium in Professional Audio Equipment. It is worth noting ROHS makes no distinction between professional and domestic uses EXCEPT when an amendment applies as in 2012/51/EU, therefore the amendment did not apply to domestic audio equipment, ever. Professional is defined as 'use by a professional' IE: by somebody working in a Professional capacity.

This amendment EXPIRED at the end of December 2013 and no extension or renewal application for it has been made or granted since...therefore the exemption for the use of "Cadmium in photoresistors for analogue optocouplers applied in professional audio equipment" under the ROHS2 directive no longer applies and never applied for domestic use, ever.

This means the importing and sale of these complete boards is illegal in the EU as it stands today. It does not matter that now alternative to an LDR is available, the legality of their use EXPIRED at the end of Dec 2013 and that legal exemption only covered Professional use.

The directive does allow though for the supply and sale of 'spare parts' where those parts are sold for the repair, reuse, updating or upgrading of specific EEE. Hence RS and Farnell can sell the LDR as a component.

With regard to some of the comments made elsewhere about other uses of cadmium and other harmful substances, yes, there is widespread use but a lot of this use is covered by specific exceptions to the directive like the use in PV panels... it's worth noting that NiCad batteries are already under 'use restriction' and that at the end of 2016 their use becomes illegal.

www.europarl.europa.eu/news/en/news-room/content/20131004IPR21519/html/MEPs-ban-cadmium-from-power-tool-batteries-and-mercury-from-button-cells