The directive itself does not address such fine point questions well, but the FAQ seems to tend towards the logic of differentiating things that can be separated from each other and still function successfully, vs. things that must be together. If they must be together, and one of the items is EEE, then the whole thing is EEE. If they can function separately successfully then they can be considered for being EEE separately.
Draft FAQ -- http://ec.europa.eu/environment/waste/rohs_eee/events_rohs3_en.htm See, for example, their discussion of lights in a clothes wardrobe. Regards, Lauren Crane From: Kunde, Brian [mailto:brian_ku...@lecotc.com] Sent: Thursday, September 06, 2012 10:53 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] RoHS Question A few weeks ago we discussed if cables were included in the RoHS Directive. I would like to take this a step further and ask if this directive applies to the non-electrical items that may be shipped with, used with, or bundled with an electronic device. For example, mouse pad, wrist pad, manuals and other documentation, disks/media, mounting stand/bracket/legs, security lock/cable, desk and/or chair (workstation), cabinets, hand tools (hex wrench, screw/nut drivers, etc.), consumables such as standards, inks, cleaners, wipes, crucibles, test strips, or packaging. And in the case where you have a cabinet, stand, or desk to which an electronic device can be or is mounted, does RoHS apply to the entire assembly or only the electronic device being that it can be separated or is a completely separate assembly? Would the WEEE directive apply to such non-electrical components if shipped with but not mechanically attached to an electronic device? Thanks for all replies and advice. The Other Brian ________________________________ LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - ---------------------------------------------------------------- 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>