John, It is a good point! The cable manufacturer is one of components and REACH governs the article, end product, not component.
Regards, Scott On 31/1/12 12:08 AM, "John Cotman" <[email protected]> wrote: > Scott, > > So far as the generator manufacturer is concerned, the small component (let¹s > imagine it¹s 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 can¹t 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, it¹s 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 I¹ve 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 ³separable part². > > With REACH, it¹s a proportion by weight of the complete product; you don¹t > 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 it¹s all in a single component, the manufacturer of > that component is also bound by REACH, since it¹s 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]> > > 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]> 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]>
