No. Only for panel materials used in the PV film, and is not a system-level exemption. By definition, substances and materials specified in the RoHS and REACH directives are considered harmful, so no exclusion for materials in other stuff.
Can you offer an 'acceptable' rationale in your D of C for the import authorities? Brian From: Regan Arndt [mailto:re...@empowermicro.com] Sent: Friday, February 17, 2017 2:05 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] RoHS and renewable energy Greetings everyone, Regarding the RoHS recast directive; DIRECTIVE 2011/65/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 8 June 2011, on the restriction of the use of certain hazardous substances in electrical and electronic equipment (recast) – see attached. Article 2 states: Scope 4. This Directive does not apply to: (i) photovoltaic panels intended to be used in a system that is designed, assembled and installed by professionals for permanent use at a defined location to produce energy from solar light for public, commercial, industrial and residential applications; 1. Does anyone know if this includes micro-inverters? I would assume so as the PV module then becomes an ‘AC PV module’ but maybe not ….. as there are more RoHS concerning components in a micro-inverter than in a DC PV module. 2. Does this exemption include combiner boxes? Does the exemption include String inverters? Rest of the BOS? I would assume so as it also states: (c) equipment which is specifically designed, and is to be installed, as part of another type of equipment that is excluded or does not fall within the scope of this Directive, which can fulfil its function only if it is part of that equipment, and which can be replaced only by the same specifically designed equipment; Most installations do not have such specific restrictions on the usage of which inverters are to be used for DC panels, etc. The directive does mention the following: (17) The development of renewable forms of energy is one of the Union’s key objectives, and the contribution made by renewable energy sources to environmental and climate objectives is crucial. Directive 2009/28/EC of the European Parliament and of the Council of 23 April 2009 on the promotion of the use of energy from renewable sources ( 4 ) recalls that there should be coherence between those objectives and other Union environmental legislation. Consequently, this Directive should not prevent the development of renewable energy technologies that have no negative impact on health and the environment and that are sustainable and economically viable. Can someone interpret the bold underlined statement above? It leads to a vague interpretation me thinks. Thanks in advance. Regan Arndt - ---------------------------------------------------------------- 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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>