We have been asking this question to several "authorities" and the conversations goes like this:
US: "Our products are marked with a RoHS logo, is that acceptable for RoHS2?" THEM: "No marks which claim compliance may be used as it confuses the meaning of the CE mark." US: "But we are not using it to claim compliance. It is a marketing tool only. A RoHS mark was never required, and thus is was never used it to claim compliance." THEM: "Here is a link to the directive and FAQ. Thanks for your enquiry." The New Approach guidelines state the reason behind the language "no other mark can be used to claim compliance" was to prevent countries from introducing their own marks. However, it seems others are taking it to mean something else. We have heard the issue will hit the courts and one enforcement agency even used the words "our current position is..." -Will William L. Brown Jr. Engineering Manager Regulatory and Compliance Tyco Security Products 6 Technology Park Drive Westford, MA 01886 USA Mobile: (978) 727 7069 Desk: (978) 577 4205 Email: willbr...@tycoint.com -----Original Message----- From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com] Sent: Thursday, September 06, 2012 14:14 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] RoHS Question A rep of the UK enforcement authority has said "yes" it would be seen as a non-conformity. All RoHS-logo's should be removed. I have a different view and the FAQ does not appear to explicitly oppose it (ref Q9. 13). What is not allowed is an alternate mark that " attests the conformity of the product with the requirements of RoHS 2". A cute RoHS logo of some other form does not, per se, do this, particularly when there are so many other "rohs type" laws in the world. "Sir, my green leaf is related to China RoHS, Korea RoHS and Japan RoHS, it has nothing to do with EU RoHS. For that, I have applied the CE mark as required." Not sure this logic will be successful, however. Regards, Lauren Crane -----Original Message----- From: Brian Oconnell [mailto:oconne...@tamuracorp.com] Sent: Thursday, September 06, 2012 12:33 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] RoHS Question Which results in another question. The FAQ states "...CE marking shall be the only marking which attests the conformity of the product with the requirements of RoHS 2." Some customers want a RoHS logo on the label. Would this extra logo be considered a non-conformity under the re-cast directive? Brian -----Original Message----- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Crane, Lauren Sent: Thursday, September 06, 2012 9:33 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] RoHS Question 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 - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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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>
