Lauren and others, I have read (I believe carefully) this FAQ.
>From Q8.14 and Directive Article 7(g) I see that product identification can be >batch number. For my understanding it is not "unique identification" called in >Annex VI. But OK let it be, I don't care because my products have unique >numbers. Q8.9 says that DoC would reference the product normally by the model number. I don't believe that ANNEX VI 1. "No....(unique identification of EEE):" means model number, but I must all the time suppose that I don't understand English good enough. Can someone tell me if unique identification of EEE can really be understand as model number ? I really don't believe! If FAQ is in opposite to directive itself than I must remember of FAQ Preface: "These FAQ reflect the views of DG Environment and as such are not legally binding: binding interpretation of EU legislation is the exclusive competence of the Court of Justice of the European Union." I still don't know if I have to issue separate DoC for each device (I have not batch numbers, but individual numbers). Q8.10 and Q9.6 directs me to EN 50581 to get presumption of conformity so it still looks that I need the declaration for each 100pcs of resistors I will order. I don't think that order saying that I order ROHS2 compliant parts and invoice saying that they are ROHS2 can be understand as "signed contract" which would allow me not to have supplier declaration. How high is in your opinion probability that if Court of Justice of European Union will have to decide if such order and such invoice can really be understand as signed contract than they will say "yes". It would help a lot if I could believe it is around 95%, but unfortunately (based on my understanding of English) I believe it is around 0%. The most surprising for me is the Q7.2. I knew that: - carrot is the fruit, - snail is the fish, - Poland, Germany and some other countries have no access to the sea, and it looks that I should add to that list that: - light is not electromagnetic field. Best Regards Piotr Galka ----- Original Message ----- From: Crane, Lauren To: Piotr Galka ; EMC-PSTC@LISTSERV.IEEE.ORG Sent: Friday, November 15, 2013 2:22 AM Subject: RE: [PSES] EN 50581 part/range of parts Piotr, Reading the EU Commission's FAQ on RoHS2 might help you http://ec.europa.eu/environment/waste/rohs_eee/pdf/faq.pdf. Components (i.e. things not intended for direct sale to the end user) are not considered to be in scope of RoHS (even though they fit the definition of EEE). It has to do with the concept of "finished product". So, if you are going to be using the 100pcs of resistors in your product, you should constrain your supplier with a contract that requires them to be RoHS compliant, but you do not need a DoC from them. Regards, Lauren Crane KLA-Tencor From: Piotr Galka [mailto:piotr.ga...@micromade.pl] Sent: Wednesday, November 13, 2013 8:27 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] EN 50581 part/range of parts To English language standard experts, How do you understand "specific part" and "specific range of parts" in last sentence in EN 50581:2012 Cl. 4.3.3 (a): "Such declarations ... shall cover a specific ... part ... or a specific range of ... parts..." According to: - directives understanding of putting product on the market (not type but single piece), - direct meaning of the words (as I fill them), it looks that: part = this one single part, range of parts = some (specified) number of the same type parts. If it is true I see problems with ROHS DoC. If I buy 100pcs of 0603 1k resistors should I ask the supplier for sending me the declaration for specified range of these 100pcs ? And the same for all 200 other types of elements ? The other way of understanding is: part = part type (resistor 0603 1k) range of parts = range of part types (resistor 0603 from 1ohm to 10Mohm) This looks more logical for someone trying to make ROHS DoC but: If they wonted to say "part type" or "range of part types" they would certainly said that. As they didn't said that I think they had the previous understanding in mind. What is the solution I don't see ? Best Regards Piotr Galka - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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