One of the most frustrating aspects of EU directives is that "placed on the market" must be assessed as the market placement of each individual unit, not a model line or similar concept. As the Commission's so called "blue-guide" states on page 18, "Moreover, the concept of placing on the market refers to each individual product, not to a type of product, and whether it was manufactured as an individual unit or in series."
So if you first started selling many units of product XYZ in 2008, the ones you place on the market in 2013 have to conform to RoHS2. Regards, Lauren Crane KLA-Tencor From: Curt McNamara [mailto:mcnam...@umn.edu] Sent: Monday, January 07, 2013 11:46 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] RoHS II The Commission has released an updated FAQ for RoHS2 Ref http://ec.europa.eu/environment/waste/rohs_eee/events_rohs3_en.htm Regards, Lauren Crane KLA-Tencor This is one of the documents I studied. It contains this phrase: "From 2nd January 2013 EEE in scope that bears a CE marking is presumed to be in conformity with the requirements of RoHS 2 and therefore is presumed not to contain more than the tolerated maximum concentration values as mentioned in Annexes II, III and IV of RoHS 2. " So what about an existing (non-exempt) product, with a DoC created at the time it was placed on the market? From the language in the official notice I am inclined to think that it is fine to keep shipping as is. >From the above, it seems that I need to have RoHS2 documentation in place as of last Friday. Which is correct? Curt On Jan 6, 2013, at 11:45 PM, Curt McNamara wrote: First off, a belated thank you to the folks that helped with a confusing requirement on buzzer loudness. Now I have a new confusing thing :-) Despite reading numerous papers, presentations, and the official notice, I am still confused about how it affects designs. Here is what I get: -- all new designs (introduced to the market now) need RoHS II compliance for CE marking ---- the substance list for RoHS II is the same as RoHS I (for now) ---- the documentation for the design elements with regards to RoHS II substances needs to be more complete ---- this documentation is part of a technical file ---- there needs to be a risk assessment in regards to whether the manufacturers that you get components from are compliant -- existing designs which were subject to RoHS I can continue to ship without the additional RoHS II documentation requirements, and can still be CE marked -- existing designs which were exempt from RoHS I have a period of time that they can continue to ship before becoming compliant. What are the glaring holes in my summary? Curt - ---------------------------------------------------------------- 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>
