Lauren, Please elaborate or what you mean by "Yep, you gotta do REACH too."
Chris ________________________________ From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of lauren_cr...@amat.com Sent: 12 December 2008 16:25 To: Nick Williams Cc: emc-p...@ieee.org Subject: Re: Revision of the WEEE and RoHS directives Nick, Yes. These proposed revisions to WEEE and RoHS are very interesting. Some of what I see; * RoHS has its "own scope" now. Essentially the Annex from WEEE has been pulled into RoHS. * For WEEE the situation is reversed - It now points to RoHS for scope. * The RoHS "spare parts" exemption is changed and, I think, eroded. Three scenarios provide exemption- military equipment; components of out-of-scope equipment that "fulfills its function only if part of that equipment"; and equipment not intended to be placed on the market as a single functional or commercial unit" - all rather vague concepts that will, no doubt, require much guidance and source much debate. * RoHS contains a new criteria prohibiting the "big 6" RoHS materials from spare parts for the repair or reuse of EEE (ref art. 4.1) * There is a new Annex III with 4 materials list and a very confusing linkage of these materials to risk assessment and the REACH candidate list in Art. 4.7 * RoHS is now a CE Marking directive (sigh....) * RoHS takes steps to make it clear that importers are "manufacturers" (regardless of whether there is an OEM external to the EU). * Use exemptions in RoHS annex V and VI are extended to be exemptions also >from REACH authorization criteria (once any get crafted). * The definition of "homogeneous material" is now defined in RoHS. * WEEE has exemptions similar to RoHS. * Both directives now kindly give a nod towards REACH and essentially say "Yep, you gotta do REACH too." * Scope of WEEE is now explicitly on waste from private households or users other than private households (this seems to be all users). I guess WEEE was just silent on this point prior. * EN 50419 is now "the" reference for the ex-bin symbol (one of the few cases where a directive mandates the use of a standard). =========== I am particularly interested in how RoHS's new treatment of integrated parts would apply in the following scenario.... A large scale stationary industrial tool (LSIT), say a printing press, is imported to the EU. It might be considered an "electrical tool" but is exempt because of the LSIT exemption in Annex I.6. The printing press has a power supply in it. The power supply manufacturer also happens to market their supply in the EU as a single commercial unit. The printing press manufacturer has no intention of marketing the power supply as a separate commercial unit, but they do provide it as a spare part in their support supply chain. Must the printing press company ensure the power supply is RoHS compliant as an industrial control instrument (controlling voltage)? Regards, Lauren Crane Product Regulatory Analyst Corporate Product EHS Lead Applied Materials Inc. Austin, TX 512 272-6540 [#922 26540] - External Use - Save paper and trees! Please consider the environment before printing this e-mail. Nick Williams <nick.willi...@conformance.co.uk> Sent by: emc-p...@ieee.org 12/12/2008 04:38 AM To emc-p...@ieee.org cc Subject Revision of the WEEE and RoHS directives I'm sure many readers here will be interested in the information at the following location: http://europa.eu/rapid/pressReleasesAct on.do?reference=IP/08/1878&format=HTML&aged=0&language=EN&guiLanguage=en Nick. - 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.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. 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