Lauren, After a week of trying to find how the need for "unique identification of EEE" should be in practice realised I have completely new idea.
Annex VI of ROHS2 looks like a recipe what point after point should be in DoC. Why identification of device is mentioned two times - in 1. and 4. ? Putting the device number at position 1. seems for me being the evident nonsense, having in mind how the typical DoC looks like (We.... declare... that device...). You mentioned three sides battling how to understand point 1. I'd like to be recognised as first being in fourth side. The fourth side: We (I hope I will not be alone) think point 1 is an error - it should call for "No... (unique identification of document):" If we assume this - everything becomes clear and logically coherent. For me it is as logic as 2+2=4. ROHS2 is based on Decision 768/2008/EC. So I looked there with hope to find the correct source version of DoC contents list. Unfortunately there is 1. ... "unique identification of the product", and 4. .... (identification of product). I can't find any reason for identifying product two times in one document. So I think Decision is the source of this error in RoHS. Some bank papers are called products :), may be someone working before in bank was editing the Decision ? May be it is possible to find same paper written before without this error. I will not try to do it. I am not good in looking for EU papers. About three weeks ago I asked the helpdesk to show me how from main new-eu-law page to go to the all directives list page (if I have to find all directives covering my product the only way is to start from the list of all). I hope they are still looking for that way to let me know :). It seems for me impossible that since 2008 no one has noticed this error. So many translators working on Decision, people working on ROHS2, translators working on ROHS2, national bodies putting ROHS2 into national law. Too long list to not find anyone thinking. I see two possibilities: 1. It is not an error - extremely hardly to believe for me. 2. All people there become used to any illogicality and just not notice the next one (one more, one less - who cares) - easier to believe for me. Am I the only seeing that "King is nude." ? Isn't it the last time to protect EMC and LVD from that error? Has anyone over there enough power and time to do it? About carrot and fish... How do you think: 1. If Pb (and others) would be in electronic equipment and in manual and both land at waste dump. Where from the water would take it faster to the ground? 2. Do the amount of CDs landing at waste dump is so small that if there are some restricted substances in their plastic it is much less care than in electronic devices? May be the direct RoHS scope interpretation saying manuals and CDs need also be RoHS is reasonable ;) Best Regards Piotr Galka ----- Original Message ----- From: Crane, Lauren To: Piotr Galka ; EMC-PSTC Sent: Thursday, November 21, 2013 1:13 AM Subject: RE: [PSES] EN 50581 part/range of parts Piotr, This topic illustrates a concept that can be called the "supremacy of practicality". I agree with you that the RoHS directive calls for "No . (unique identification of the EEE):" in the DoC. What I have learned is that the EU legislation as a collective is not really sure what this means, exactly. There appear to be two/three sides battling. Side 1 - people who think each product unit should have a unique number and that should be placed in a unique DoC for that particular unit. Side 2 - people who think only a general product descriptor (e.g., model name) should be required in the DoC. Side 3 - people who think a DoC can cover several unique units provided the unit number range (serial number range) is expressed in the DoC. Currently both the Low Voltage Directive and the EMC Directive are being recast. You can observe parliament and the council struggling with this issue. Here, for example, is an excerpt from a current mid-process document for the EMC Directive recast regarding the requirements for the DoC. Commission Proposal - " No . (unique identification of the apparatus): " Parliament Position - "No . (identification of the apparatus):" Council Position - "Product/Apparatus (product, batch, type or serial number )" Expected compromise/outcome -> [Council Position] As long as DoCs reasonably express the identification of covered products, I think in the current legislative environment, any practical solution will be acceptable. There is certainly enough evidence that 1 - there is a preference that one DoC be provided for all applicable directives (rather than a separate DoC for each applicable directive) and 2 - directives are not completely harmonized on how the covered product(s) must be identified. ==== 50581 allows "supplier declarations, confirming that the restricted substance content of the material, part, or sub-assembly is within the permitted levels and identifying any exemptions that have been applied." - I think an invoice from a supplier stating the provided resistors could qualify as a such a declaration, provided they mention exemptions used, if any. ==== Regarding your carrots and fish.. I am sympathetic to your surprise. I think the EEE definition has some severe problems and in the "cold light of day" would include CDs and perhaps even paper manuals (which require light to be legible), but there are also legal principles that suggest laws, no matter how they are worded, must be interpreted reasonably. I think the FAQ has provided some good boundaries on reasonable interpretation with Q7.2. Regards, Lauren Crane KLA-Tencor From: Piotr Galka [mailto:[email protected]] Sent: Tuesday, November 19, 2013 10:02 AM To: EMC-PSTC; Crane, Lauren Subject: Re: [PSES] EN 50581 part/range of parts 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 ; [email protected] 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:[email protected]] Sent: Wednesday, November 13, 2013 8:27 AM To: [email protected] 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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