But does the generator manufacturer have to worry about it if they ship so many generators that the total weight of the cable ties exceeds 1 metric tonne in a year?
Dan From: John Cotman [mailto:[email protected]] Sent: Monday, January 30, 2012 11:09 AM To: [email protected] Subject: Re: [PSES] REACH - a concentration of 0.1% (w/w). Scott, So far as the generator manufacturer is concerned, the small component (let's imagine it's a cable tie) being made 100% from a restricted substance does not cause the generator to breach REACH (because its weight is a very small fraction of the generator. But the generator manufacturer probably does not make the component in house; he will buy it in. The cable tie manufacturer is also subject to REACH. His product is cable ties and he can't sell cable ties that breach the limit. John C ________________________________ From: Scott Xe [mailto:[email protected]] Sent: 30 January 2012 13:50 To: [email protected] Subject: Re: [PSES] REACH - a concentration of 0.1% (w/w). John, Thanks for your explanation. With REACH, it's a proportion by weight of the complete product. If at the worst, the SVHC is used in a single component, why it is not allowed. It is counted on the complete product, not individual component. Regards, Scott On 30/1/12 6:00 PM, "John Cotman" <[email protected]> wrote: Scott, Not quite sure if I understand your question, but RoHS and REACH approach the concentration issue differently. In RoHS, you are not permitted to exceed the concentration of a restricted substance in any separable part. The effect of this, which I've personal experience of, is that a complete electrical product fails because of excess hexavalent chrome in the plating of tiny terminal screws, because the plating can be scraped off the screw and is therefore treated as a "separable part". With REACH, it's a proportion by weight of the complete product; you don't break it into pieces. The effect of this, in theory, is that a large generator, say, weighing several tons, could have a few Kg of something quite nasty in it. However, if it's all in a single component, the manufacturer of that component is also bound by REACH, since it's a product in its own right. Not sure if this helps? John C ________________________________ From: Scott Xe [mailto:[email protected]] Sent: 28 January 2012 09:43 To: [email protected] Subject: [PSES] REACH - a concentration of 0.1% (w/w). Recently, there is a discussion about the permissible concentration of 0.1% for SVHCs. If a component is smaller than 0.1% (w/w), the article is considered acceptable even though the component consists of 100% SVHC. I believe the REACH regulation is to regulate SVHCs not to be used in the product. It does not mean the product is allowed to use small amount of SVHCs. It is similar to RoHS directive. The original directive did not allow any content of hazardous substances. However, other EU member points out that in production, even though it does not use the hazardous substances, it may have pollution into the production units. It is unavoidable and does not mean you can intentionally add the hazardous substances to the permissible level. Can anyone be aware if REACH adopts the same from RoHS directive. Thanks, Scott - ---------------------------------------------------------------- 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 <[email protected]> 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 <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher <[email protected]> David Heald <[email protected]> - ---------------------------------------------------------------- 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 <[email protected]> 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 <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher <[email protected]> David Heald <[email protected]> - ---------------------------------------------------------------- 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 <[email protected]<mailto:[email protected]>> 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 <[email protected]<mailto:[email protected]>> Mike Cantwell <[email protected]<mailto:[email protected]>> For policy questions, send mail to: Jim Bacher <[email protected]<mailto:[email protected]>> David Heald <[email protected]<mailto:[email protected]>> - ---------------------------------------------------------------- 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 <[email protected]<mailto:[email protected]>> 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 <[email protected]<mailto:[email protected]>> Mike Cantwell <[email protected]<mailto:[email protected]>> For policy questions, send mail to: Jim Bacher <[email protected]<mailto:[email protected]>> David Heald <[email protected]<mailto:[email protected]>> - ---------------------------------------------------------------- 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 <[email protected]> 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 <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher: <[email protected]> David Heald: <[email protected]>
