Hmmm. I’ve taken a RoHS seminar and have done some research on the net that has led me to believe that individual cables (although compliant with the requirements) don’t need to be CE marked until 2019.
http://www.digitaleurope.org/Portals/0/Documents/DIGITALEUROPE%20Input%20RoHS%202%20FAQ%2020110930.pdf “Option B (fallback) Cables ready for enduse (cordsets with plugs on each end) placed on the market as separate products are defined by Article 3(5) “cables means all cables with a rated voltage of less than 250 volts that serve as a connection or an extension to connect EEE to the electrical outlet or to connect two or more EEE to each other”. The Commission interprets Article 2(2) as meaning that electrical and electronic equipment which was outside the scope of Directive 2002/95/EC, but which would be covered by the new Directive, does not need to comply with the requirements of this Directive during a transitional period of eight years. EEE which was outside the scope of Directive 2002/95/EC, but which would be covered by the new Directive, includes among others EEE, "cables" mentioned in Article 4 and the related definition in Article 3(5)." Cables (as defined in Article 3(5)) fall under Category 11, and the substance restrictions and the DoC/CE marking requirements therefore apply from 22nd July 2019 (8 years after entry into force).” My cable vendors are also in line with this interpretation. Does anyone know if there has been an “official” interpretation of this? It seems to me there might be a lot of cables stuck in customs come January if they are looking for a CE mark and DoC. Patty Knudsen Product Safety Engineering 17095 Via del Campo San Diego, CA 92127 858-485-3748 Teradata Labs [email protected] <mailto:[email protected]%0b>teradata.com<http://www.teradata.com/> Facebook<https://www.facebook.com/Teradata> The information contained in this message is private and confidential, is the property of Teradata Corporation, and is solely for the use of its intended recipient. If you are not the person to whom this e-mail is addressed, or if it has been sent to you in error, please notify the sender immediately. If you are not the intended recipient, please note that permission to use, copy, disclose, alter or distribute this message, and any attachments, is expressly denied. Please consider the environment before printing. From: Monrad Monsen [mailto:[email protected]] Sent: Wednesday, August 22, 2012 5:32 PM To: Knudsen, Patricia Cc: [email protected] Subject: Re: [PSES] CE Marking of Power Cables 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 [email protected] <mailto:[email protected]%0b>teradata.com<http://www.teradata.com/> The information contained in this message is private and confidential, is the property of Teradata Corporation, and is solely for the use of its intended recipient. If you are not the person to whom this e-mail is addressed, or if it has been sent to you in error, please notify the sender immediately. If you are not the intended recipient, please note that permission to use, copy, disclose, alter or distribute this message, and any attachments, is expressly denied. Please consider the environment before printing. From: Monrad Monsen [mailto:[email protected]] Sent: Tuesday, August 21, 2012 4:50 PM To: [email protected]<mailto:[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 - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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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]>
