Lauren,

 

Thanks for the link to the ERA report.   There's some excellent information
in there.  I wish that their recommendations had made it into the recast for
cat 8 and 9.  I noted that one of their examples of industrial monitoring
and control is a bench-top LCR meter which is clearly test and measurement
equipment.

 

While it's true that the control exemption expires in 2017, it would be a
big help to apply that exemption at this time in this particular case.

 

Carl

 

From: Crane, Lauren [mailto:[email protected]] 
Sent: Tuesday, July 09, 2013 3:45 PM
To: Carl Newton; [email protected]
Subject: RE: [PSES] RoHS 2 - Definition of Industrial Monitoring Equipment

 

I have experience with the question, but no experience getting a good
answer. 

 

I have had the opinion that test and measurement equipment is different from
monitoring and control equipment, but apparently, many companies used the
old WEEE+RoHS exclusion from RoHS for monitoring and control equipment to
get their test and measurement equipment out of scope also, so there is some
inertia in interpretations that prevents heading in a different direction
(i.e., that test and measurement is different from monitoring and control).


 

The Commission has little 'shame' over the lack of a clear definition
because, after all, everything will be in scope in a few years anyway. 

 

You might find some value in the ERA study done on cat 8 & 9  prior to
RoHS2. It has some more explanation and examples. It is not, of course,
legally binding, but it was done by some well-reasoned folk, IMO.  

 

Ref. http://ec.europa.eu/environment/waste/pdf/era_study_final_report.pdf

 

Regards,

Lauren Crane

KLA-Tencor

 

From: Carl Newton [mailto:[email protected]] 
Sent: Tuesday, July 09, 2013 1:06 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

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