Re: [PSES] RoHS Question
FYI: I received an email from a/the Policy Officer for RoHS for the European Commission. Referencing REGULATION (EC) No 765/2008 Article 30 (4): The CE marking shall be the only marking which attests the conformity of the product with the applicable requirements of the relevant Community harmonization legislation providing for its affixing. Though we might think of these marks as marketing only and not "marks of conformity," he replies: "What do you want to attest with these logos other than conformity with RoHS?" These logos make a statement regarding a product's conformity to RoHS, and any marking which states you conform with the requirements of RoHS is no longer allowed (as the CE mark can be the only mark with attest the conformity). Not sure how to get a more authoritative answer. I did reply for follow-up, but have received no reply. -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 From: Brown, William [mailto:willbr...@tycoint.com] Sent: Friday, September 07, 2012 11:45 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] RoHS Question One interpretation we received: National Measurement Office of the Department for Business Innovation and Skills (www.nmo.gov.uk) The recast RoHS Directive was published in the Official Journal of the European Union on 1 July 2011 and entered into force on 21 July 2011. It will be transposed into national law on 2 January 2013. The RoHS Directive is now a CE Marking Directive. The general principles governing the CE marking are set out in Regulation (EC) No 765/2008. It should also be noted that point 21 of the preamble of the RoHS Directive states that: "Procedures for assessing the conformity of EEE subject to this Directive should be consistent with relevant Union legislation, in particular Decision No 768/2008/EC of the European Parliament and of the Council of 9 July 2008 on a common framework for the marketing of products. Harmonising conformity assessment procedures should give manufacturers legal certainty as to what they have to provide as proof of compliance to the authorities throughout the Union." Regulation 768/2008/EC establishes a common framework for the marketing of products and states in the preamble that: (29) The CE marking, indicating the conformity of a product, is the visible consequence of a whole process comprising conformity assessment in a broad sense. General principles governing the CE marking are set out in Regulation (EC) No 765/2008 of the European Parliament and the Council of 9 July 2008 setting out the requirements for accreditation and market surveillance relating to the marketing of products. Rules governing the affixing of the CE marking, to be applied in Community harmonisation legislation providing for the use of that marking, should be laid down in this Decision. (30) The CE marking should be the only marking of conformity indicating that a product is in conformity with Community harmonisation legislation. However, other markings may be used as long as they contribute to the improvement of consumer protection and are not covered by Community harmonisation legislation. (31) It is crucial to make clear to both manufacturers and users that by affixing the CE marking to a product the manufacturer declares that the product is in conformity with all applicable requirements and that he takes full responsibility therefore. This clearly indicates that RoHS symbols or other markings should not be used as a conformity mark [WB - emphasis added]. For information the Commission has published an FAQ consultation paper which provides clarity on this point. On page 25 it states that: "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. From 2nd January 2013, CE marking shall be the only marking which attests the conformity of the product with the requirements of RoHS 2." The 'phase in period' is considered as beginning on entry into force (21 July 2011) and ending upon transposition into national law (2 January 2013). Therefore products placed on the market on or after 2 January 2013 must comply with all requirements of RoHS Directive 2011/65/EU. The term placing on the market is the initial action of making a product available for the first time on the Community market, with a view to distribution or use in the Community. This is considered to take place when a product is transferred from the stage of manufacture with the intention of distribution or use on the Community market and applies to each individual product, and not a type, series or line of
Re: [PSES] RoHS Question
> From: Ron Pickard [mailto:rpick...@equinoxpayments.com] > Sent: Thursday, September 06, 2012 09:30 > > Brian, > Further to Mark's reply, please note that compliance to > the recast RoHS Directive is to be indicated in a > product's DofC (Article 13) and CE marking (Article > 16). > > IMHO, a CE marked product itself must adhere to the > requirements of any EU directives that are applicable > to it including the recast RoHS Directive. It's also important to note that the former RoHS Dir. only applied to those products covered by the WEEE Dir. The RoHS recast removed this limitation of applicability. However, in Article 2, "2. Without prejudice to Article 4(3) and 4(4), Member States shall provide that EEE that was outside the scope of Directive 2002/95/EC, but which would not comply with this Directive, may nevertheless continue to be made available on the market until 22 July 2019." So products are not, strictly speaking, required to comply with the RoHS recast now, if they were out of scope previously. These products are allowed to apply the CE mark until mid 2019. Regards, Peter Tarver This email message is for the sole use of the intended recipient(s) and may contain confidential and/or privileged information. If you are not an intended recipient, you may not review, use, copy, disclose or distribute this message. If you received this message in error, please contact the sender by reply email and destroy all copies of the original message. - 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 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 Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
Re: [PSES] RoHS Question
Not certain that this a question of adjudication, but rather implementation. The EU does not have functional equivalent of administrative law? Or is this an intended effect of comitology? Napoleon or Napoleonic Code? But what would (most of) the lawyers do without case law? Brian -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of John Woodgate Sent: Friday, September 07, 2012 10:28 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] RoHS Question In message , dated Fri, 7 Sep 2012, Brian Oconnell writes: >Someone from the other side of the pond needs to explain to the >colonists which organizations publish binding opinions. None, if you mean interpretative responses to questions. It's not legally permitted. Parliament writes the laws and the only authority that may interpret them is the court system. In my opinion, many of the EU Directives have created chaos, and of course no-one with the power to fix the problems will admit they exist. Bring back Napoleon, as long as he doesn't get into the Channel Tunnel! (;-) -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk The longer it takes to make a point, the more obtuse it proves to be. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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 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 Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
Re: [PSES] RoHS Question
publish binding opinions? I was told only courts in the EU can do that. Chuck McDowell Meyer Sound Laboratories Inc. -Original Message- From: [mailto:emc-p...@ieee.org] On Behalf Of Brian Oconnell Sent: Friday, September 07, 2012 10:01 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] RoHS Question They seem to be the UK body for OIML representation. Do not know what this has to do with enforcement of marking directives. Someone from the other side of the pond needs to explain to the colonists which organizations publish binding opinions. From the website with the URL www.bis.gov.uk/nmo <http://www.bis.gov.uk/nmo> : Our mission To provide policy support to Ministers on measurement issues and a measurement infrastructure which enables innovation and growth, promotes trade and facilitates fair competition and the protection of consumers, health and the environment. -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Brown, William Sent: Friday, September 07, 2012 8:45 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] RoHS Question One interpretation we received: National Measurement Office of the Department for Business Innovation and Skills ( www.nmo.gov.uk <http://www.nmo.gov.uk> ) The recast RoHS Directive was published in the Official Journal of the European Union on 1 July 2011 and entered into force on 21 July 2011. It will be transposed into national law on 2 January 2013. The RoHS Directive is now a CE Marking Directive. The general principles governing the CE marking are set out in Regulation (EC) No 765/2008. It should also be noted that point 21 of the preamble of the RoHS Directive states that: "Procedures for assessing the conformity of EEE subject to this Directive should be consistent with relevant Union legislation, in particular Decision No 768/2008/EC of the European Parliament and of the Council of 9 July 2008 on a common framework for the marketing of products. Harmonising conformity assessment procedures should give manufacturers legal certainty as to what they have to provide as proof of compliance to the authorities throughout the Union." Regulation 768/2008/EC establishes a common framework for the marketing of products and states! in the preamble that: (29) The CE marking, indicating the conformity of a product, is the visible consequence of a whole process comprising conformity assessment in a broad sense. General principles governing the CE marking are set out in Regulation (EC) No 765/2008 of the European Parliament and the Council of 9 July 2008 setting out the requirements for accreditation and market surveillance relating to the marketing of products. Rules governing the affixing of the CE marking, to be applied in Community harmonisation legislation providing for the use of that marking, should be laid down in this Decision. (30) The CE marking should be the only marking of conformity indicating that a product is in conformity with Community harmonisation legislation. However, other markings may be used as long as they contribute to the improvement of consumer protection and are not covered by Community harmonisation legislation. (31) It is crucial to make clear to both manufacturers and users that by affixing the CE marking to a product the manufacturer declares that the product is in conformity with all applicable requirements and that he takes full responsibility therefore. This clearly indicates that RoHS symbols or other markings should not b! e used as a conformity mark [WB - emphasis added]. For information the Commission has published an FAQ consultation paper which provides clarity on this point. On page 25 it states that: "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. From 2nd January 2013, CE marking shall be the only marking which attests the conformity of the product with the requirements of RoHS 2." The 'phase in period' is considered as beginning on entry into force (21 July 2011) and ending upon transposition into national law (2 January 2013). Therefore products placed on the market on or after 2 January 2013 must comply with all requirements of RoHS Directive 2011/65/EU. The term placing on the market is the initial action of making a product available for the first time on the Community market, with a view to distribution or use in the Community. This is considered to take place when a product is transferred from the stage of manufacture with the intention of distribution or use on the Community market and applies to each individual product, and not a type, series or line of product. I hope that this clarification re. use of RoHS symbols makes sense and is of use. -
Re: [PSES] RoHS Question
In message , dated Fri, 7 Sep 2012, Brian Oconnell writes: Someone from the other side of the pond needs to explain to the colonists which organizations publish binding opinions. None, if you mean interpretative responses to questions. It's not legally permitted. Parliament writes the laws and the only authority that may interpret them is the court system. In my opinion, many of the EU Directives have created chaos, and of course no-one with the power to fix the problems will admit they exist. Bring back Napoleon, as long as he doesn't get into the Channel Tunnel! (;-) -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk The longer it takes to make a point, the more obtuse it proves to be. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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 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 Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
Re: [PSES] RoHS Question
They seem to be the UK body for OIML representation. Do not know what this has to do with enforcement of marking directives. Someone from the other side of the pond needs to explain to the colonists which organizations publish binding opinions. From the website with the URL www.bis.gov.uk/nmo <http://www.bis.gov.uk/nmo> : Our mission To provide policy support to Ministers on measurement issues and a measurement infrastructure which enables innovation and growth, promotes trade and facilitates fair competition and the protection of consumers, health and the environment. -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Brown, William Sent: Friday, September 07, 2012 8:45 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] RoHS Question One interpretation we received: National Measurement Office of the Department for Business Innovation and Skills ( www.nmo.gov.uk <http://www.nmo.gov.uk> ) The recast RoHS Directive was published in the Official Journal of the European Union on 1 July 2011 and entered into force on 21 July 2011. It will be transposed into national law on 2 January 2013. The RoHS Directive is now a CE Marking Directive. The general principles governing the CE marking are set out in Regulation (EC) No 765/2008. It should also be noted that point 21 of the preamble of the RoHS Directive states that: "Procedures for assessing the conformity of EEE subject to this Directive should be consistent with relevant Union legislation, in particular Decision No 768/2008/EC of the European Parliament and of the Council of 9 July 2008 on a common framework for the marketing of products. Harmonising conformity assessment procedures should give manufacturers legal certainty as to what they have to provide as proof of compliance to the authorities throughout the Union." Regulation 768/2008/EC establishes a common framework for the marketing of products and states in the preamble that: (29) The CE marking, indicating the conformity of a product, is the visible consequence of a whole process comprising conformity assessment in a broad sense. General principles governing the CE marking are set out in Regulation (EC) No 765/2008 of the European Parliament and the Council of 9 July 2008 setting out the requirements for accreditation and market surveillance relating to the marketing of products. Rules governing the affixing of the CE marking, to be applied in Community harmonisation legislation providing for the use of that marking, should be laid down in this Decision. (30) The CE marking should be the only marking of conformity indicating that a product is in conformity with Community harmonisation legislation. However, other markings may be used as long as they contribute to the improvement of consumer protection and are not covered by Community harmonisation legislation. (31) It is crucial to make clear to both manufacturers and users that by affixing the CE marking to a product the manufacturer declares that the product is in conformity with all applicable requirements and that he takes full responsibility therefore. This clearly indicates that RoHS symbols or other markings should not be used as a conformity mark [WB - emphasis added]. For information the Commission has published an FAQ consultation paper which provides clarity on this point. On page 25 it states that: "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. From 2nd January 2013, CE marking shall be the only marking which attests the conformity of the product with the requirements of RoHS 2." The 'phase in period' is considered as beginning on entry into force (21 July 2011) and ending upon transposition into national law (2 January 2013). Therefore products placed on the market on or after 2 January 2013 must comply with all requirements of RoHS Directive 2011/65/EU. The term placing on the market is the initial action of making a product available for the first time on the Community market, with a view to distribution or use in the Community. This is considered to take place when a product is transferred from the stage of manufacture with the intention of distribution or use on the Community market and applies to each individual product, and not a type, series or line of product. I hope that this clarification re. use of RoHS symbols makes sense and is of use. -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 <mailto:willbr...@tycoint.com> - This message is from the
Re: [PSES] RoHS Question
One interpretation we received: National Measurement Office of the Department for Business Innovation and Skills (www.nmo.gov.uk) The recast RoHS Directive was published in the Official Journal of the European Union on 1 July 2011 and entered into force on 21 July 2011. It will be transposed into national law on 2 January 2013. The RoHS Directive is now a CE Marking Directive. The general principles governing the CE marking are set out in Regulation (EC) No 765/2008. It should also be noted that point 21 of the preamble of the RoHS Directive states that: "Procedures for assessing the conformity of EEE subject to this Directive should be consistent with relevant Union legislation, in particular Decision No 768/2008/EC of the European Parliament and of the Council of 9 July 2008 on a common framework for the marketing of products. Harmonising conformity assessment procedures should give manufacturers legal certainty as to what they have to provide as proof of compliance to the authorities throughout the Union." Regulation 768/2008/EC establishes a common framework for the marketing of products and states in the preamble that: (29) The CE marking, indicating the conformity of a product, is the visible consequence of a whole process comprising conformity assessment in a broad sense. General principles governing the CE marking are set out in Regulation (EC) No 765/2008 of the European Parliament and the Council of 9 July 2008 setting out the requirements for accreditation and market surveillance relating to the marketing of products. Rules governing the affixing of the CE marking, to be applied in Community harmonisation legislation providing for the use of that marking, should be laid down in this Decision. (30) The CE marking should be the only marking of conformity indicating that a product is in conformity with Community harmonisation legislation. However, other markings may be used as long as they contribute to the improvement of consumer protection and are not covered by Community harmonisation legislation. (31) It is crucial to make clear to both manufacturers and users that by affixing the CE marking to a product the manufacturer declares that the product is in conformity with all applicable requirements and that he takes full responsibility therefore. This clearly indicates that RoHS symbols or other markings should not be used as a conformity mark [WB - emphasis added]. For information the Commission has published an FAQ consultation paper which provides clarity on this point. On page 25 it states that: "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. From 2nd January 2013, CE marking shall be the only marking which attests the conformity of the product with the requirements of RoHS 2." The 'phase in period' is considered as beginning on entry into force (21 July 2011) and ending upon transposition into national law (2 January 2013). Therefore products placed on the market on or after 2 January 2013 must comply with all requirements of RoHS Directive 2011/65/EU. The term placing on the market is the initial action of making a product available for the first time on the Community market, with a view to distribution or use in the Community. This is considered to take place when a product is transferred from the stage of manufacture with the intention of distribution or use on the Community market and applies to each individual product, and not a type, series or line of product. I hope that this clarification re. use of RoHS symbols makes sense and is of use. -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 From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com] Sent: Friday, September 07, 2012 11:06 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] RoHS Question Nick, I completely agree with your first point. One of the 'counterfit' discussions that has gone around is related to a 'Chinese Export' mark where the font was the same but the spacing between the 'C' and the 'E' was diminished. There was even a YouTube cast posted from an EU Parliamentarian alerting the world to the issue. However, there is much commentary suggesting it was all a myth born of a joke (ref http://www.cemarking.net/chinese-export/). Regarding your second point, I would love to see the details of what the UK enforcement authorities got wrong. Can you share the details or point to an article, etc... (this may read as defensive, but I am truly interested) Regards, Lauren Crane From: Nick Williams [mailto:nick.willi...@
Re: [PSES] RoHS Question
Nick, I completely agree with your first point. One of the 'counterfit' discussions that has gone around is related to a 'Chinese Export' mark where the font was the same but the spacing between the 'C' and the 'E' was diminished. There was even a YouTube cast posted from an EU Parliamentarian alerting the world to the issue. However, there is much commentary suggesting it was all a myth born of a joke (ref http://www.cemarking.net/chinese-export/). Regarding your second point, I would love to see the details of what the UK enforcement authorities got wrong. Can you share the details or point to an article, etc... (this may read as defensive, but I am truly interested) Regards, Lauren Crane From: Nick Williams [mailto:nick.willi...@conformance.co.uk] Sent: Thursday, September 06, 2012 5:28 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] RoHS Question I don't have any clearer answer than those already been given by Lauren Crane and William Brown, but a couple of points occur which may be grist to the mill. Firstly, I suspect that the original intention of including wording in the Directive to restrict the use of other marks has, at least in part, grown from the New Legislative Framework requirement intended to protect the CE mark, and so the intention was not to outlaw other marks per-se, but was to outlaw other marks which might be confused with (and taken to mean the same as) a legitimate CE mark. Secondly, and somewhat less conjecturally, the UK enforcement authority turned out to be spectacularly wrong in their interpretation of at least one aspect of the old Directive (the large scale industrial tools exemption) and so I'd be inclined to take anything else they say with a pinch of salt as well. Nick. On 6 Sep 2012, at 20:10, Brown, William wrote: Nick Williams Director Direct line: +44 1298 873811 Mobile: +44 7702 995135 email: nick.willi...@conformance.co.uk - Conformance Ltd - Product safety, approvals and CE-marking consultants The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk Registered in England, Company No. 3478646 - 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 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 Mike Cantwell For policy questions, send mail to: Jim Bacher David Heald - 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 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 Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
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." A cursory read through the actual directive does not appear to preclude affixing any marking or symbol whatsoever. Of course, the CE mark must be applied and in accordance with the Directive. Assuming this is the case (it was a cursory read through) Article 16(1) of the directive requires that Member States must presume the conformity of CE marked goods unless there is hard evidence to the contrary. I would challenge any OEO (Officious Enforcement Official) that any sort of logo (RoHS or otherwise) is most certainly not hard evidence of non-conformance and unless they can present other tangible evidence they themselves are contravening Article 16 of European Directive 2011/65/EU. T - Original Message - From: Crane, Lauren Sent: 09/06/12 07:13 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 whic! h 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 wa! rdrobe. 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 separ ate assembly? Would the WEEE directive apply to such non-electrical co! mponents 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. To post a message to the list, send your e-mail to 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
Re: [PSES] RoHS Question
I don't have any clearer answer than those already been given by Lauren Crane and William Brown, but a couple of points occur which may be grist to the mill. Firstly, I suspect that the original intention of including wording in the Directive to restrict the use of other marks has, at least in part, grown from the New Legislative Framework requirement intended to protect the CE mark, and so the intention was not to outlaw other marks per-se, but was to outlaw other marks which might be confused with (and taken to mean the same as) a legitimate CE mark. Secondly, and somewhat less conjecturally, the UK enforcement authority turned out to be spectacularly wrong in their interpretation of at least one aspect of the old Directive (the large scale industrial tools exemption) and so I'd be inclined to take anything else they say with a pinch of salt as well. Nick. On 6 Sep 2012, at 20:10, Brown, William wrote: Nick Williams Director Direct line: +44 1298 873811 Mobile: +44 7702 995135 email: nick.willi...@conformance.co.uk - Conformance Ltd - Product safety, approvals and CE-marking consultants The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk Registered in England, Company No. 3478646 - 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 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 Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
Re: [PSES] RoHS Question
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. To post a message to the list, send your e-mail to 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 Communiti
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. To post a message to the list, send your e-mail to 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 Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald: - 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 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 Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
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. To post a message to the list, send your e-mail to 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 Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
Re: [PSES] RoHS Question
There are other applicable EU directives that address other issues like packaging, batteries and of course REACH. If you are shipping product to China then China RoHS applies and things like cables, cd's, plastics and basically any accessory is targeted. These items may exceed the limit (similar or equal to EU RoHS) but must be disclosed in the form of a disclosure table that ships with the product. Regards, Mark From: Ron Pickard [mailto:rpick...@equinoxpayments.com] Sent: Thursday, September 06, 2012 12:30 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] RoHS Question Brian, Further to Mark's reply, please note that compliance to the recast RoHS Directive is to be indicated in a product's DofC (Article 13) and CE marking (Article 16). IMHO, a CE marked product itself must adhere to the requirements of any EU directives that are applicable to it including the recast RoHS Directive. Accessory items such as you've described may or may not have other EU directives applicable to them. Comments? IHTH. Best regards, Ron From: Mark Schmidt [mailto:mark.schm...@dornerworks.com] Sent: Thursday, September 06, 2012 8:59 AM To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] RoHS Question In both cases it is directed at electrical and electronic equipment. Mark From: Kunde, Brian [mailto:brian_ku...@lecotc.com]<mailto:[mailto:brian_ku...@lecotc.com]> Sent: Thursday, September 06, 2012 11:53 AM To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto: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 mailto: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 mailto:emcp...@radiusnorth.net>> Mike Cantwell mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org>> David Heald mailto: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 mailto: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 mailto:emcp...@radiusnorth.net>> Mike Cantwell mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org>> David Heald mailto: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
Re: [PSES] RoHS Question
That was most helpful. Thank you. From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Crane, Lauren Sent: Thursday, September 06, 2012 12:33 PM 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<mailto: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 mailto: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 mailto:emcp...@radiusnorth.net>> Mike Cantwell mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org>> David Heald mailto: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 mailto: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 mailto:emcp...@radiusnorth.net>> Mike Cantwell mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org>> David Heald mailto:dhe...@gmail.com>> 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 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.i
Re: [PSES] RoHS Question
I followed the link. Q1.2 says Q1.s What is the difference between Directive 2002/95/EC (RoHS1) and Directive 2011/65/EU (RoHS2)? There are key differences between RoHS 1 and RoHS 2 in the following areas: 1. Scope A gradual extension of the requirements to all electrical and electronic equipment (EEE), cables and spare parts with a view to full compliance by 22nd July 2019 Gary From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com] 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 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 mailto: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 mailto:emcp...@radiusnorth.net>> Mike Cantwell mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org>> David Heald mailto: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 mailto: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 mailto:emcp...@radiusnorth.net>> Mike Cantwell mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org>> David Heald mailto: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 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 for
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 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 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 Mike Cantwell For policy questions, send mail to: Jim Bacher David Heald - 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 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 Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
Re: [PSES] RoHS Question
Brian, Further to Mark's reply, please note that compliance to the recast RoHS Directive is to be indicated in a product's DofC (Article 13) and CE marking (Article 16). IMHO, a CE marked product itself must adhere to the requirements of any EU directives that are applicable to it including the recast RoHS Directive. Accessory items such as you've described may or may not have other EU directives applicable to them. Comments? IHTH. Best regards, Ron From: Mark Schmidt [mailto:mark.schm...@dornerworks.com] Sent: Thursday, September 06, 2012 8:59 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] RoHS Question In both cases it is directed at electrical and electronic equipment. Mark From: Kunde, Brian [mailto:brian_ku...@lecotc.com]<mailto:[mailto:brian_ku...@lecotc.com]> Sent: Thursday, September 06, 2012 11:53 AM To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto: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 mailto: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 mailto:emcp...@radiusnorth.net>> Mike Cantwell mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org>> David Heald mailto: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 mailto: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 mailto:emcp...@radiusnorth.net>> Mike Cantwell mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org>> David Heald mailto: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 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 Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
Re: [PSES] RoHS Question
other stuff seems to be covered by REACH... http://ec.europa.eu/environment/chemicals/reach/reach_intro.htm From: Mark Schmidt To: "Kunde, Brian" ; "EMC-PSTC@LISTSERV.IEEE.ORG" Sent: Thursday, September 6, 2012 11:58 AM Subject: RE: RoHS Question In both cases it is directed at electrical and electronic equipment. Mark From:Kunde, Brian [mailto:brian_ku...@lecotc.com] Sent: Thursday, September 06, 2012 11:53 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 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 Mike Cantwell For policy questions, send mail to: Jim Bacher David Heald - 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 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 Mike Cantwell For policy questions, send mail to: Jim Bacher David Heald - 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 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 Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
Re: [PSES] RoHS Question
In both cases it is directed at electrical and electronic equipment. Mark From: Kunde, Brian [mailto:brian_ku...@lecotc.com] Sent: Thursday, September 06, 2012 11:53 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 mailto: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 mailto:emcp...@radiusnorth.net>> Mike Cantwell mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org>> David Heald mailto: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 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 Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
