Brian: The following is omitted from the summary: - Gather and evaluate recast RoHS compliance data - Assure Internal Production Control for recast RoHS - Perform periodic testing for compliance with recast RoHS - Assure non-compliant product are not placed on EU market starting 2013
Samuel -----Original Message----- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Brian Oconnell Sent: Friday, February 17, 2012 1:47 PM To: Emc-Pstc (E-mail) Subject: EU NLF directives reference this: <http://ec.europa.eu/enterprise/policies/single-market-goods/regulatory-poli cies-common-rules-for-products/new-legislative-framework/> Doing some reading in prep for RoHS recast reporting. After reading the NLF regs (765/2008, 768/2008) and the proposals for LVD and EMCD recast, and losing much karma through brain leakage, I have summarized these affects: 1. Everyone in the 'chain' is responsible. While all 'economic operators' are said to be responsible, there are some that may not be legally held accountable. 2. Each EU state will have a sole national accreditation body as regulatory and to grant accreditation. 3. The 'CE' mark should be the sole indicator of conformity, and must display (adjacent) the ID of the NB. All NLF-affected stuff shall be serialized and marked with a product identification; shall have instructions; shall have mfr contact info. All languages where placed on market must be addressed for DofC and manual (is Klingon an EU language?). 4. Import fees or some other additional tax will be required to support accreditation and surveillance bodies. 5. All test facilities will have to be accredited to act as a 3d party lab. 6. Any state can submit a 'reasoned request', and the mfr/rep must provide all required data. So all CE-marked electrical stuff must have a TF/TCF and D of C. 7. Mfrs/importers/reps/distributers must determine that the product is compliant. 8. All NBs will be subject to peer review, and the CABs/NBs have some level of liability. 9. ISO 9k/14k factory registration becomes pro forma requirement. 10. Self declaration may no longer be possible for anything scoped by RoHS, LVD, and/or EMCD. 11. All records, including TF, DofC, test records, inspections, et al have 10year retention. Did I miss any important points? Do any of above have incorrect interpretation? Brian - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
