Chris,
Elaboration --> It is frustrating how many laws in general in a country, and
the EU specifically (though not a country), affect similar classes of products
but do not reference each other. For example, a small aerosol can of
specialized oil for a machine might be within scope of the EU Narcotics
Precursor Regulation, the REACH Regulation, the Dangerous Preparations
Directive, the Aerosol Dispensers Directive and the Prepackaged Products
directive, but the laws do not always cross reference each other (though there
is some). In this same way, EEE within scope of RoHS could easily contain
materials relevant to the restrictions of REACH (Annex XVII) or the "Candidate
List" materials of REACH. It is nice to see the RoHS directive explicitly
mention REACH (see the following) and to say it applies even though RoHS might
also. REACH, of course, is the acronym for Regulation 1907/2006.
Reference to REACH -> "This Directive shall apply without prejudice to
requirements of Community legislation on safety and health, on chemicals, in
particular Regulation (EC) 1907/2006 as well as of specific Community waste
management legislation."
Hope that helps
Lauren
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"James, Chris" <[email protected]>
12/15/2008 03:35 AM To
Lauren Crane/APPLIED MATERIALS@AMAT
cc
<[email protected]>, "Nick Williams" <[email protected]>
Subject
RE: Revision of the WEEE and RoHS directives
Lauren,
Please elaborate or what you mean by "Yep, you gotta do REACH too."
Chris
________________________________
From: [email protected] [mailto:[email protected]] On Behalf Of
[email protected]
Sent: 12 December 2008 16:25
To: Nick Williams
Cc: [email protected]
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]
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Nick Williams <[email protected]>
Sent by: [email protected]
12/12/2008 04:38 AM
To
[email protected]
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.
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