"A rep of the UK enforcement authority has said "yes" it would be seen as a non-conformity. All RoHS-logo's should be removed." A cursory read through the actual directive does not appear to preclude affixing any marking or symbol whatsoever. Of course, the CE mark must be applied and in accordance with the Directive. Assuming this is the case (it was a cursory read through).... Article 16(1) of the directive requires that Member States must presume the conformity of CE marked goods unless there is hard evidence to the contrary. I would challenge any OEO (Officious Enforcement Official) that any sort of logo (RoHS or otherwise) is most certainly not hard evidence of non-conformance and unless they can present other tangible evidence they themselves are contravening Article 16 of European Directive 2011/65/EU. T
----- Original Message ----- From: Crane, Lauren Sent: 09/06/12 07:13 PM To: [email protected] Subject: Re: [PSES] RoHS Question A rep of the UK enforcement authority has said "yes" it would be seen as a non-conformity. All RoHS-logo's should be removed. I have a different view and the FAQ does not appear to explicitly oppose it (ref Q9. 13). What is not allowed is an alternate mark that " attests the conformity of the product with the requirements of RoHS 2". A cute RoHS logo of some other form does not, per se, do this, particularly when there are so many other "rohs type" laws in the world. "Sir, my green leaf is related to China RoHS, Korea RoHS and Japan RoHS, it has nothing to do with EU RoHS. For that, I have applied the CE mark as required." Not sure this logic will be successful, however. Regards, Lauren Crane -----Original Message----- From: Brian Oconnell [mailto:[email protected]] Sent: Thursday, September 06, 2012 12:33 PM To: [email protected] Subject: Re: [PSES] RoHS Question Which results in another question. The FAQ states "...CE marking shall be the only marking whic! h attests the conformity of the product with the requirements of RoHS 2." Some customers want a RoHS logo on the label. Would this extra logo be considered a non-conformity under the re-cast directive? Brian -----Original Message----- From: [email protected] [mailto:[email protected]]On Behalf Of Crane, Lauren Sent: Thursday, September 06, 2012 9:33 AM To: [email protected] Subject: RE: [PSES] RoHS Question The directive itself does not address such fine point questions well, but the FAQ seems to tend towards the logic of differentiating things that can be separated from each other and still function successfully, vs. things that must be together. If they must be together, and one of the items is EEE, then the whole thing is EEE. If they can function separately successfully then they can be considered for being EEE separately. Draft FAQ -- http://ec.europa.eu/environment/waste/rohs_eee/events_rohs3_en.htm See, for example, their discussion of lights in a clothes wa! rdrobe. Regards, Lauren Crane From: Kunde, Brian [mailto:[email protected]] Sent: Thursday, September 06, 2012 10:53 AM To: [email protected] Subject: [PSES] RoHS Question A few weeks ago we discussed if cables were included in the RoHS Directive. I would like to take this a step further and ask if this directive applies to the non-electrical items that may be shipped with, used with, or bundled with an electronic device. For example, mouse pad, wrist pad, manuals and other documentation, disks/media, mounting stand/bracket/legs, security lock/cable, desk and/or chair (workstation), cabinets, hand tools (hex wrench, screw/nut drivers, etc.), consumables such as standards, inks, cleaners, wipes, crucibles, test strips, or packaging. And in the case where you have a cabinet, stand, or desk to which an electronic device can be or is mounted, does RoHS apply to the entire assembly or only the electronic device being that it can be separated or is a completely separ ate assembly? Would the WEEE directive apply to such non-electrical co! mponents if shipped with but not mechanically attached to an electronic device? Thanks for all replies and advice. The Other Brian - ---------------------------------------------------------------- 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]> 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]>
