Chris, My company also manufacturers equipment that fall into the grey zone of Categories 8 & 9, but we are taking the view that we should comply with the directive for the following reasons:
* the non-inclusion of Cats 8 & 9 in the scope, is subject to a pending review and is likely to be removed (by 2008?) * commercial pressure from component suppliers and board manufacturers & suppliers will push us towards compliance anyway, as they will not supply or maintain facilities for leaded production. regards, Dave Coleman From: [email protected] mailto:[email protected]] On Behalf Of Chris Maxwell Sent: 20 April 2005 20:38 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 ********************************************************************** IMPORTANT NOTICE The information contained in this e-mail is confidential. It may also be legally privileged. It is intended only for the stated addressee(s) and access to it by any other person is unauthorised. If you are not an addressee, you must not disclose, copy, circulate or in any other way use or rely on the information contained in this e-mail. Such unauthorised use may be unlawful. If you have received this e-mail in error, please inform Racal Instruments Group Ltd. immediately by emailing [email protected] or phoning +44 (0)1202 872800 (ask for the I.T. Dept.) and delete it and all copies from your system. www.racalinstrumentsgroup.co.uk ********************************************************************** ---------------------------------------------------------------- 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
