I have some European colleagues who say that CE stands for Can't Enforce. But you really should make things ROHS if you want to sell them in the US or Japan.
If it's not ROHS, then it isn't. Maybe it has lead solder joints inside.
Lithiums now need explicit overcharge/short circuit protection, which is a fairly new requirement. Even if a shorted battery does nothing dramatic.
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John Larkin Highland Technology, Inc
jlarkin at highlandtechnology dot com
http://www.highlandtechnology.com
Precision electronic instrumentation
Picosecond-resolution Digital Delay and Pulse generators
Custom laser drivers and controllers
Photonics and fiberoptic TTL data links
VME thermocouple, LVDT, synchro acquisition and simulation
ROHS is not enforced, and there are exemptions e.g. Control and Monitoring equipment (yes very useful :))
The real issue is if you are sent a form to fill in by a large customer which actually asks you to state there is no lead and sign it. They are not legally entitled to do that IF you can use the exemption but they are free to do it in a business context e.g. they are free to insist the product contains no copper...
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