Mr. Woodgate is offering a rational interpretation in the face of an inconsistent and confused bureaucracy. The problem is that the import authorities may or may not agree for all cases of related equipment. Depending on the particular state’s import authorities and the particular equipment being imported, they have previously disallowed the RoHS ‘exemption’ for inverters and/or combiner boxes; and one such rejected assembly had a combiner box that was attached to a PV Panel.
Confused in an anomalous wet desert, Brian From: John Woodgate [mailto:jmw1...@btinternet.com] Sent: Monday, February 20, 2017 1:14 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] RoHS and renewable energy I agree with your interpretation. I don't think it means that only an inverter specified by type number by the manufacturer of the PV module is exempt. What would be the point of such a restriction (not that EU regulations necessarily have a point!)? With best wishes DESIGN IT IN! OOO – Own Opinions Only www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England Sylvae in aeternum manent. From: Regan Arndt [mailto:re...@empowermicro.com] Sent: Monday, February 20, 2017 9:04 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] RoHS and renewable energy Thanks Brian. I cannot find an 'example of' or a 'definition' as to what constitutes 'specifically designed' within the directive. If I read the exemption clause below, it can be interpreted that 'equipment specifically designed' (i.e. micro inverter)…………..as 'part of another type of equipment' (i.e. PV module). Note that a micro inverter (for all intents and purposes) can only be used with a PV module and cannot be used with any other device (i.e. computer peripheral), thus it could (or at least should) be classified as 'equipment specifically designed'. (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; Any further help from you directly or from the EMC-PSTC team on obtaining a formal clarification is greatly appreciated. Thanks in advance. Regan -----Original Message----- From: Brian O'Connell [mailto:oconne...@tamuracorp.com] Sent: Friday, February 17, 2017 2:44 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] RoHS and renewable energy 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. 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