Chris,
Is that your read of the current RoHS or the revision proposal? My question is
related to the revision proposal. This is what I see....
________________________________
Original RoHS said....
This Directive does not apply to: spare parts for the repair, or to the reuse,
of electrical and electronic equipment put on the market before 1 July 2006.
[Art 2.3]
Proposed Change says
This Directive does not apply to:
(a) equipment which is necessary for the protection of the essential interests
of the security of Member States, including arms, munitions and war material
intended for specifically military purposes ;
(b) equipment which is specifically designed as part of another type of
equipment that does not fall within the scope of this Directive and can
fulfill its function only if it is part of that equipment;
(c) equipment which is not intended to be placed on the market as a single
functional or commercial unit.
[Art 2.3]
So getting exemption here depends on
* clearly understanding "can fulfill its function only if is part of that
equipment" - It seems a PSU can still fulfill its function of providing power,
in or out of a printing press.
OR
* demonstrating that the PSU is not being placed on the market as a single
functional or commercial unit - but what exactly is meant by "single
functional unit" or "commercial unit"? No defs. are provided.
Further, later in the proposal it is stated
Member States shall ensure that EEE, including spare parts for its repair or
its reuse placed on the market does not contain the substances listed in Annex
IV {the big 6}. [Art 4.1]
With some exceptions
4. Paragraph 1 shall not apply to spare parts for the repair or to the reuse
of the following:
(a) EEE placed on the market before 1 July 2006.
(b) Medical devices placed on the market before 1st January 2014.
(c) In vitro diagnostic medical devices placed on the market before 1st
January 2016.
(d) Monitoring and control instruments placed on the market before 1st January
2014.
(e) Industrial monitoring and control instruments placed on the market before
1st January 2017.
(f) EEE which benefited from an exemption and was placed on the market before
that exemption expired.
So the PSU which might be considered a monitoring and control instrument in
its own right, is a spare part for the printing press (a electrical tool) and
so may only benefit from (a), but if the particular printing press being
repaired was placed on the market this year, there is no available exemption.
Regards,
Lauren
- external use -
Save paper and trees! Please consider the environment before printing this
e-mail.
"James, Chris" <c...@dolby.co.uk>
12/15/2008 03:14 AM To
Lauren Crane/APPLIED MATERIALS@AMAT
cc
<emc-p...@ieee.org>, "Nick Williams" <nick.willi...@conformance.co.uk>
Subject
RE: Revision of the WEEE and RoHS directives
Lauren,
If the PSU is being supplied as a spare to repair a product not in scope then
the spare can be rohs or non-rohs so there would be no need to prove it is
RoHS.
Chris
________________________________
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of
lauren_cr...@amat.com
Sent: 12 December 2008 16:25
To: Nick Williams
Cc: emc-p...@ieee.org
Subject: Re: Revision of the WEEE and RoHS directives
Nick,
Yes. These proposed revisions to WEEE and RoHS are very interesting.
Some of what I see;
* RoHS has its "own scope" now. Essentially the Annex from WEEE has been
pulled into RoHS.
* For WEEE the situation is reversed - It now points to RoHS for scope.
* The RoHS "spare parts" exemption is changed and, I think, eroded. Three
scenarios provide exemption- military equipment; components of out-of-scope
equipment that "fulfills its function only if part of that equipment"; and
equipment not intended to be placed on the market as a single functional or
commercial unit" - all rather vague concepts that will, no doubt, require much
guidance and source much debate.
* RoHS contains a new criteria prohibiting the "big 6" RoHS materials from
spare parts for the repair or reuse of EEE (ref art. 4.1)
* There is a new Annex III with 4 materials list and a very confusing
linkage
of these materials to risk assessment and the REACH candidate list in Art. 4.7
* RoHS is now a CE Marking directive (sigh....)
* RoHS takes steps to make it clear that importers are "manufacturers"
(regardless of whether there is an OEM external to the EU).
* Use exemptions in RoHS annex V and VI are extended to be exemptions also
>from REACH authorization criteria (once any get crafted).
* The definition of "homogeneous material" is now defined in RoHS.
* WEEE has exemptions similar to RoHS.
* Both directives now kindly give a nod towards REACH and essentially say
"Yep, you gotta do REACH too."
* Scope of WEEE is now explicitly on waste from private households or
users
other than private households (this seems to be all users). I guess WEEE was
just silent on this point prior.
* EN 50419 is now "the" reference for the ex-bin symbol (one of the few
cases
where a directive mandates the use of a standard).
===========
I am particularly interested in how RoHS's new treatment of integrated parts
would apply in the following scenario....
A large scale stationary industrial tool (LSIT), say a printing press, is
imported to the EU. It might be considered an "electrical tool" but is exempt
because of the LSIT exemption in Annex I.6.
The printing press has a power supply in it. The power supply manufacturer
also happens to market their supply in the EU as a single commercial unit.
The printing press manufacturer has no intention of marketing the power supply
as a separate commercial unit, but they do provide it as a spare part in their
support supply chain.
Must the printing press company ensure the power supply is RoHS compliant as
an industrial control instrument (controlling voltage)?
Regards,
Lauren Crane
Product Regulatory Analyst
Corporate Product EHS Lead
Applied Materials Inc.
Austin, TX 512 272-6540 [#922 26540]
- External Use -
Save paper and trees! Please consider the environment before printing this
e-mail.
Nick Williams <nick.willi...@conformance.co.uk>
Sent by: emc-p...@ieee.org
12/12/2008 04:38 AM
To
emc-p...@ieee.org
cc
Subject
Revision of the WEEE and RoHS directives
I'm sure many readers here will be interested in the information at
the following location:
http://europa.eu/rapid/pressReleasesAct
on.do?reference=IP/08/1878&format=HTML&aged=0&language=EN&guiLanguage=en
Nick.
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