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Chris,
For reasons other than yours, my company is excluded from the scope of the directive; however we have decided to go through the steps to compliance. This was a well though out decision and we have decided to go ahead. We have a few compelling reasons: 1) Our OEM customers are requesting compliance. 2) It won’t be long before component parts will become unavailable. 3) It is viewed as a marketing advantage. Maybe I’m dating myself but I began work in the elctronics world in the early 70’s near the time when transitors were replacing vacuum tubes. Item #2 is reminiscent of that time. Doug Powell Staff Engineer Corporate Compliance Dept. Advanced Energy Industries Inc. _____ From: [email protected] mailto:[email protected]] On Behalf Of Chris Maxwell Sent: Wednesday, April 20, 2005 1:38 PM To: [email protected] Subject: RoHS and WEEE I have a question regarding interpretation of exemptions to the RoHS Directive (2002/95/EC). Specifically, Article 2, paragraph 1 of the RoHS Directive states that the directive shall apply to products falling under the categories 1, 2, 3, 4, 5, 6, 7 and 10 set out in Annex 1A to the WEEE Directive (2002/96/EC) Notice that categories 8 and 9 are left out…so, if you go to Annex 1A of the WEEE directive, you’ll find the definitions of categories 8 and 9. Category 8 is medical devices. We are particularly interested in category 9, which is “Monitoring and control instruments.” Category 9 is further explained in Annex 1B of the directive, where examples are given. Examples: Smoke Detector Heating Regulators Thermostats ---Measuring, weighing or adjusting appliances for household or as laboratory equipment ---Other monitoring and control instruments used in industrial installations (e.g. in control panels) I have put dashes in front of the last two lines because they are of interest to my colleagues. We have embarked on a RoHS compliance program. Some of our colleagues are saying that it’s unjustified effort because our equipment is exempt under the last two statements above. So here is my question…We make fiber optic test measurement equipment (power meters, light sources, OTDRs…) do they fall under “measuring” appliances for household or as laboratory equipment??? I have said not because they are field portable instruments which almost never get used in a house; and rarely in a lab. We are occasionally used in “industrial installations” for monitoring; but rarely. So, I wouldn’t think that this exemption applies either. Any takers on interpreting this? Are there any good resources for resolving such questions? Is there a “Guidelines” document for the RoHS Directive published by CENELEC yet? Thanks in advance for any thoughts you may have. Chris Maxwell Design Engineer Nettest ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to [email protected] Instructions: http://listserv.ieee.org/listserv/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas [email protected] Mike Cantwell [email protected] For policy questions, send mail to: Richard Nute: [email protected] Jim Bacher: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
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Chris, For reasons other than yours, my company
is excluded from the scope of the directive; however we have decided to go
through the steps to compliance. This was a well though out decision and
we have decided to go ahead. We have a few compelling reasons: 1) Our OEM customers are requesting
compliance. 2) It won’t be long
before component parts will become unavailable. 3) It is viewed as a
marketing advantage. Maybe I’m dating myself but I began work in the elctronics
world in the early 70’s near the time when transitors were replacing
vacuum tubes. Item #2 is reminiscent of that time. Doug Powell Staff Engineer Corporate Compliance Dept. Advanced Energy Industries Inc. From: [email protected]
[mailto:[email protected]] On
Behalf Of Chris Maxwell I have a question regarding interpretation of exemptions to
the RoHS Directive (2002/95/EC). Specifically, Article 2, paragraph 1 of the RoHS
Directive states that the directive shall apply to products falling under
the categories 1, 2, 3, 4, 5, 6, 7 and 10 set out in Annex 1A to the WEEE
Directive (2002/96/EC) Notice that categories 8 and 9 are left out…so, if you
go to Annex 1A of the WEEE directive, you’ll find the definitions of
categories 8 and 9. Category 8 is medical devices. We are
particularly interested in category 9, which is “Monitoring and control
instruments.” Category 9 is further explained in Annex 1B of the
directive, where examples are given. Examples: Smoke Detector Heating Regulators Thermostats ---Measuring, weighing or adjusting appliances for household
or as laboratory equipment ---Other monitoring and control instruments used in
industrial installations (e.g. in control panels) I have put dashes in front of the last two lines
because they are of interest to my colleagues. We have embarked on a RoHS
compliance program. Some of our colleagues are saying that it’s
unjustified effort because our equipment is exempt under the last two
statements above. So here is my question…We make fiber optic test
measurement equipment (power meters, light sources, OTDRs…) do they
fall under “measuring” appliances for household or as laboratory
equipment??? I have said not because they are field portable
instruments which almost never get used in a house; and rarely in a lab. We are occasionally used in “industrial
installations” for monitoring; but rarely. So, I wouldn’t
think that this exemption applies either. Any takers on interpreting this? Are there any good resources for resolving such questions?
Is there a “Guidelines” document for the RoHS Directive published
by CENELEC yet? Thanks in advance for any thoughts you may have. Chris Maxwell Design Engineer Nettest To post a message to the list, send your e-mail to [email protected] Instructions: http://listserv.ieee.org/listserv/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas [email protected] Mike Cantwell [email protected] For policy questions, send mail to: Richard Nute: [email protected] Jim Bacher: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc |
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