Moldova's Technical Regulation restricting hazardous substances in electrical and electronic equipment (HG 643/2025, Monitorul Oficial Nr. 526-528 art. 675), adopted by the Government on October 1, 2025 and published on October 10, 2025, enters into force on October 10, 2026, transposing Directive 2011/65/EU (RoHS) as last amended by Delegated Directive (EU) 2024/1416 under Law 277/2018 and Law 209/2016.
From October 10, 2026, Moldovan importers of electrical and electronic equipment (EEE), manufacturers and authorised representatives placing EEE on the Moldovan market, distributors and retailers, and EU and third-country EEE exporters must ensure equipment meets the Annex 2 substance limits with technical documentation drawn up and CE marking plus an EU Declaration of Conformity (or the national SM conformity mark) affixed, or non-compliant EEE may not be placed on the Moldovan market and faces withdrawal and market-access refusal enforced by the Environmental Protection Inspectorate.
- Deadline : October 10, 2026 (HG 643/2025 enters into force; Annex 2 substance limits and conformity-assessment duties apply)
- Who : Manufacturers, authorised representatives, importers and distributors placing Annex 1 EEE categories on the Moldovan market
- What : Meet the Annex 2 substance limits and draw up technical documentation with CE marking and an EU Declaration of Conformity, or the SM conformity mark
- Otherwise : Non-compliant EEE barred from the Moldovan market; withdrawal and market-access refusal by the Environmental Protection Inspectorate
- Official source : HG nr. 643/2025 (legis.md)
What is due on October 10, 2026
Four obligations fall due when HG 643/2025 enters into force on October 10, 2026. Manufacturers, authorised representatives, importers and distributors placing Annex 1 EEE categories on the Moldovan market must not place on the market equipment containing Annex 2 restricted substances (lead, mercury, cadmium, hexavalent chromium, PBB, PBDE and the phthalates DEHP, BBP, DBP, DIBP) above the maximum concentration values in homogeneous materials, subject to Annex 3 exemptions. Producers or authorised representatives must draw up technical documentation and affix CE marking with an EU Declaration of Conformity; until EU accession, national-market EEE assessed under Annex 7 may instead bear the SM conformity mark, and CE marking removes the need for the SM mark on the same equipment.
The Government adopted HG 643/2025 on October 1, 2025 and published it on October 10, 2025; the general entry into force follows 12 months after publication. Points 15, 16, 63 and 66 to 68 and Annex 5 are deferred until the ACAA (conformity assessment and industrial products acceptance) ratification law enters into force. The Ministry of Environment must approve the harmonised standards list before entry into force and monitors and updates the Technical Regulation in line with EU amendments; the Environmental Protection Inspectorate controls execution.
| Step | Date |
|---|---|
| Adopted by the Government | October 1, 2025 |
| Published in Monitorul Oficial | October 10, 2025 |
| Entry into force | October 10, 2026 |
Who is covered
Manufacturers, authorised representatives, importers and distributors placing Annex 1 EEE categories (consumer electronics, IT, household appliances and lighting within scope) on the Moldovan market are covered, together with EU and third-country exporters shipping regulated equipment into Moldova. The regulation transposes Directive 2011/65/EU (RoHS) as last amended by Delegated Directive (EU) 2024/1416, so EEE carrying a valid EU Declaration of Conformity and CE marking satisfies the substance-limit and conformity duties without the additional SM mark. Annex 3 exemptions apply to specific applications where no technically viable substitute exists. Categories subject to the deferred points remain governed by the prior regime until the ACAA ratification law enters into force.
What to do before October 10, 2026
- Screen bills of materials and homogeneous-material declarations against the Annex 2 maximum concentration values (lead 0.1%, mercury 0.1%, cadmium 0.01%, hexavalent chromium 0.1%, phthalates 0.1%), applying Annex 3 exemptions where they apply.
- Draw up the technical documentation demonstrating conformity with the substance limits, including test reports and supplier declarations.
- Affix CE marking with a valid EU Declaration of Conformity, or, for national-market EEE assessed under Annex 7 until EU accession, the SM conformity mark with a national declaration of conformity.
- Confirm the EEE category falls within Annex 1 and is not deferred under points 15, 16, 63, 66 to 68 or Annex 5.
- Update supplier contracts and importer due-diligence flows to require RoHS substance declarations for equipment shipped to Moldova.
- Brief customs and market-surveillance contacts for Environmental Protection Inspectorate controls from October 10, 2026.
What happens otherwise
EEE that does not meet the Annex 2 substance limits or bear the required conformity marking may not be placed on the Moldovan market from October 10, 2026. The Environmental Protection Inspectorate (Inspectoratul pentru Protecția Mediului) controls execution of HG 643/2025, with powers including withdrawal of non-compliant equipment and refusal of market access; the Ministry of Environment monitors and updates the Technical Regulation and must approve the harmonised standards list. The deferred points are not a general exemption: the substance-limit and conformity-assessment duties apply to all in-scope EEE from the entry-into-force date. Continuous per-jurisdiction monitoring surfaces such application dates as they are fixed in the law.
