Carl,
It depends on how the product is marketed and who it is sold to. Also, was the standard used for evaluation part of the EN 61010-x family, which would then ensure it is part of Measurement and Control Equipment. In the 12 December 2012 version of the RoHS2 FAQ, which is he first one I accessed from my library, Q6.2 says that "RoHS2 does not distinguish between consumer and Industrial and professional products, other than by timeline and when they fall into the scope of RoHS 2." Q6.9 says: Q6.9 How should "professional use" be interpreted? Does it apply only at the first placing on the market, or also at later stages? "Professional use", as referred to in the exclusion of non-road mobile machinery and the definition of industrial monitoring and control, refers to the use phase of the EEE. In order for EEE to be marketed for "professional use", its intended end user has to be a professional. It should also be noted that RoHS 2 does not differentiate between EEE for professional or non-professional use other than in a few exclusions. These exclusions explicitly state that the equipment concerned is made available only for professional use, in order for the exclusion to apply. In some cases a manufacturer may place EEE on the market with the intent that it is only used for professional use. However a distributor outside the control of the manufacturer may make the EEE available for a non-professional use (for example through sale or hire). In these cases the distributor is modifying the purpose of the EEE and therefore may be taking on the responsibility for the compliance of the EEE (Article 11). The RoHS2 implementation date for 'industrial and professional' Measurement and Control Equipment is 22 July 2017. Since your product is handheld and installed as a permanent part of the product you do not benefit from the LSAT exemption to RoHS2. Steve Brody Product EHS Consulting LLC [email protected] www.productehsconsulting.com From: Carl Newton [mailto:[email protected]] Sent: Tuesday, July 09, 2013 2:06 PM To: [email protected] Subject: [PSES] RoHS 2 - Definition of Industrial Monitoring Equipment Group, I'm trying to find some reputable definitions of industrial monitoring equipment as it relates to RoHS 2. There is a very brief reference in the WEEE Directive Annex IB which refers to equipment installed within an industrial control panel, and that example is much too narrow. The official RoHS 2 FAQ doesn't address the question. I'm dealing with a handheld device that is used to measure flatness on brake rotors within industrial environments. I think that it would be accurate to consider it test and measurement equipment. However, what should be considered to be industrial monitoring? I'm trying to understand whether a piece of test equipment such as this which is used to MONITOR the quality of a finished manufactured product qualifies as an industrial monitoring device within the context of RoHS 2. Although I realize that my last sentence appears to answer the question, what I'm really after are sources of information, ideally official, which expands upon the definition of industrial monitoring equipment. Does anyone on this list have experience with this question? Thanks much, Carl - ---------------------------------------------------------------- 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]>
