John:

 

Here is the link to CA SB 50, Chapter 863

 

http://www.boe.ca.gov/sptaxprog/sb_50_bill_20040929_chaptered.htm

 

Samuel Lifshutz

Manager QA

MRV Communications Inc.  

20520 Nordhoff Street

Chatsworth, CA 91311, USA

Tel: (818) 772-6235 x265

Fax: (818) 772-0576

email: slifsh...@mrv.com

www.mrv.com

Registered by QMI to ISO 9001:2000 

 

 

  _____  

From: Samuel Lifshutz 
Sent: Tuesday, December 21, 2004 2:15 PM
To: Tyra, John; jeff collins
Cc: emc-p...@ieee.org
Subject: RE: RoHS / WEEE Directive Questions

 

Hi John:

 

Good clarification of a covered electronic device in California Senate Bill 50.

 

The Section 1 of the California Senate Bill No.50, Chapter 863 provides
reference the EU RoHS Directive 2002/95/EC.

 

I attached the SB 50, but the posting to the EMC-PSTC list has been rejected
because it contains an attachment of type 'APPLICATION/OCTET-STREAM'.  

 

Happy Holidays!

 

Samuel Lifshutz

Manager QA

MRV Communications Inc.  

20520 Nordhoff Street

Chatsworth, CA 91311, USA

Tel: (818) 772-6235 x265

Fax: (818) 772-0576

email: slifsh...@mrv.com

www.mrv.com

Registered by QMI to ISO 9001:2000 

 

 

  _____  

From: Tyra, John [mailto:john_t...@bose.com] 
Sent: Tuesday, December 21, 2004 10:34 AM
To: Samuel Lifshutz; jeff collins
Cc: emc-p...@ieee.org
Subject: RE: RoHS / WEEE Directive Questions

 

Hello Samuel,

 

Excellent synopsis on the coming regulations!

 

I ran this past our Environmental Group and they had the following
clarification on the California Regs and info on Taiwan which might of
interest to the group:

 

California's SB-50 only applies to the following video display products not to
all electronic equipment

# Cathode ray tube containing devices (CRT devices) with CRTs greater than
four inches measured diagonally (X)

# Cathode ray tubes (CRTs) greater than four inches measured diagonally (X);

# Computer monitors containing cathode ray tubes greater than four inches
measured diagonally (X) 

# Laptop computers with liquid crystal display (LCD) screens greater than four
inches measured diagonally (X)

# LCD containing desktop monitors greater than four inches measured diagonally
(X) 

# Televisions containing cathode ray tubes greater than four inches measured
diagonally (X)

Televisions containing liquid crystal display (LCD) screens greater than four
inches measured diagonally (X) (added December 2004)

Plasma televisions with screens greater than four inches measured diagonally
(X) (added December 2004)

There is no comparison between prop 65 and any of these directives.  Prop 65
does not actually ban anything.  It requires notification if consumers may be
exposed to harmful levels.

 

Taiwan has also recently passed rules which may require compliance to RoHS for
sales to Taiwan.

 

Have a happy and safe Holiday everyone........

 

Best regards,

 

John Tyra

Product Safety and Regulatory

Compliance Manager 

Bose Corporation

The Mountain, MS-450

Framingham, MA 01701-9168

phone: 508-766-1502

fax: 508-766-1145


From: owner-emc-p...@listserv.ieee.org 
mailto:owner-emc-p...@listserv.ieee.org] On Behalf Of Samuel Lifshutz
Sent: Monday, December 20, 2004 6:24 PM
To: jeff collins
Cc: emc-p...@ieee.org
Subject: RE: RoHS / WEEE Directive Questions

Jeff:

 

My research on the subject,

 

The “Green” law applies to Electrical & Electronic products with a cord,
or a battery (There are few exemptions). 

 

California Senate Bill 50 signed into law 9/29/04, effective immediately:

 

1.       Bans sale of RoHS non-compliant devices as of 1 January 2007

2.       Requires manufacturers to notify all retailers, by 1 October 2004,
which of manufactured products are subject to the waste recycling fee

3.       Requires retailers to collect recycling fees from 1 January 2005

4.       On or before 1, July 2005, and annually thereafter, requires each
manufacturer of covered devices to submit a report to the Cal Integrated Waste
on sales volumes and hazardous substances used.

 

Japanese legislation introduced voluntary compliance law in 2002.

 

China regulations follow RoHS & WEEE Directives from 1 July 2006.

 

Other, like EPA, Maine, Washington, Oregon, Maryland, Minnesota, New Jersey,
Alberta, Ontario and Australia, established or considering recycling programs.

 

Products put on the market after 1 July 2006 (RoHS Directive) shall not exceed
the limits of maximum allowed concentration for the following substances:

1.       Lead - Pb                                              .1%

2.       Mercury - Hg                                         .1%

3.       Cadmium - (Cd)                                     .01%

4.       Hexavalent Chromium - Cr(Vi)                 .1%

5.       Polybrominated biphenyls – PBB            .1%

6.       Polybrominated diphenyl ethers – PBDE  .1%

 

*         Producer will be required to issue a Supplier’s Declaration on
RoHS conformity

*         Producer will have to obtain assurance (Supplier’s Declaration)
>from their suppliers that materials/components comply with ROHS concentration
levels

*         Producer may wish to undertake own analysis (budget $ for analysis
services) for verification, or where no Supplier Declaration exists

*         The enforcement authority will carry out market surveillance and may
conduct tests by unscrewing, cutting, crushing, grinding and abrasive
processes to measure maximum concentration by weight in homogeneous materials.

 

On offences and penalties:

1.       For failing to submit compliance documentation liable to a fine up to
level 5 on standard scale

2.       For failing to comply with RoHS could result in unlimited fine on
conviction on indictment

3.       Allows for a third party prosecution

 

On WEEE Directive:

 

*         Products sold in after 13 August 2005 (WEEE Directive) shall have a
label (a symbol) that it is a subject to collection for recycling (Will be
checked by Customs)

*         Producers options for collection are: 

1.       Take back arrangements

2.       Membership of distributor compliance scheme with state-approved
recyclers and assumption of the cost.

 

Registration to ISO 14000 is not de-facto compliance to ROHS & WEEE.

 

Regards,

 

Samuel Lifshutz

 

 


  _____  


From: jeff collins [mailto:jeffcollin...@yahoo.com] 
Sent: Monday, December 20, 2004 1:15 PM
To: emc-p...@ieee.org
Subject: RoHS / WEEE Directive Questions

 

Group,

 

I'm working on a project assessing compliance to these two directives which
are mandatory in the EU.  I have come up with the following questions that may
be of concern to others involved with these directives.

 

* Many of the RoHS/WEEE restricted substances are also restricted in the State
of California under Proposition 65. Is anyone addressing CA. Prop 65
compliance and is there any daylight between it and RoHS/WEEE?

 

* Is the EPA in the US implementing or in the process of implementing similar
restrictions? If so when and will it parallel RoHS and WEEE.

 

* How do these directives tie into a manufacturer that has achieved ISO 14000
compliance, evidenced by a independent 3rd party agency? Can the ISO 14000
certification be considered as compliance by defacto to the RoHS/WEEE
Directives? Has anyone looked at comparing ISO 14K to the RoHS and WEEE
Directive. ( IS0 14K is a guideline regarding the impact to the environment
through an environmental management scheme)

 

 

Thanks in advance,

 

Jeff Collins

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