Patricia,
Great comment! However, I notice that RoHS 1 (Directive 2002/95/EC)
does state in article 3 (definitions) paragraph (a) that "'EEE' means
... equipment for the ... transfer ... of such currents and fields ...
and designed for use with a voltage rating not exceeding 1000 volts for
alternating current and 1500 volts for direct current". Therefore, it
appears that power cables and electrical communications cables were in
scope for RoHS 1, but RoHS 1 was not a CE marking directive and did not
require DOCs. Instead, RoHS 1 only required that the cables comply with
not using the hazardous substances in homogenous materials in excess of
the limits. The problem is that RoHS 2 now requires CE marking,
manufacturer name & address, and a DOC. As a result, the due date seems
to be 3 January 2013. (Article 26)
My understanding is that optical fibre cables would be out-of-scope
(exempt).
Note: All opinions given in this e-mail are purely my own and do not
necessarily reflect the positions of any company I work for.
Monrad
On 8/22/2012 4:06 PM, Knudsen, Patricia wrote:
Cables have a transition period for compliance to RoHS recast until
July 2019, per article 2.2:
“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.”
The U.S. Department of Commerce has a pretty decent FAQ for RoHS Recast:
http://www.ita.doc.gov/td/standards/Markets/Western%20Europe/European%20Union/Webpage%20RoHS%20II%20FAQ%20final.pdf
Patty Knudsen
Product Safety Engineering
17095 Via del Campo
San Diego, CA 92127
858-485-3748
Teradata Labs
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*From:*Monrad Monsen [mailto:[email protected]]
*Sent:* Tuesday, August 21, 2012 4:50 PM
*To:* [email protected]
*Subject:* [PSES] CE Marking of Power Cables
Must power cables imported and sold in Europe have a CE mark and
manufacturer's name & address starting 3 January 2013 in accordance
with the recast RoHS Directive 2011/65/EU? Similarly, must the power
cable have its own declaration of conformity (DOC)?
It appears that AC power cables shipped in separate boxes would meet
the definition of EEE in article 3 definition (1) as the AC power
cable is "/equipment for the ... transfer ... of such currents and
fields and designed for use with a voltage rating not exceeding 1 000
volts for alternating current/".
For companies that sell worldwide, many ship the power cables alone in
their own boxes separate from the system products since their products
are sold worldwide and the correct power cable must be selected for
each order as applicable for each customer's country. Usually, the
power cable is imported in the same shipment as the system, but there
are other times when the power cable is imported alone either to
replace a damaged power cable (field replacement unit) or sold to
support moving a product already in Europe to change plug types
(different plugs used for moves to other countries within Europe or to
different power distribution units). Hence, it would appear that power
cables would need to comply with the European rules individually for
compliance instead of depending on the system product (like a server)
for the CE marking.
As a result, it appears that power cables will now require a CE mark,
be labeled with the manufacturer's name & address, and have its own
DOC by 3 January 2013.
Note: All opinions given in this e-mail are purely my own and do not
necessarily reflect the positions of any company I work for.
Thanks.
Monrad Monsen
+1.303.272.9612
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