Our motivation for including information on our EU DoCs that may not be technically required is two-fold; 1. to better inform our customers, and 2. to reduce the number of questions/complaints from the field. We could drastically reduce the number of requests from the field if we provide the information on the DoC; in this case, the 2015/863 amendment. I agree that technically it should not be necessary, but there are benefits here to consider. And as far as I know, there is no rule against it. So why not?
BTW, thanks to everyone who participated in this thread. It has been very informative and I appreciate it. Have a great Thanksgiving if you celebrate such a thing. We have the next few days off which I'm looking forward to. Brian On Sun, Nov 22, 2020 at 4:47 AM Charlie Blackham < [email protected]> wrote: > A lot of articles were published when 2015/863 was published, so people > are more aware of it that the other amendments, but RoHS compliance is very > much a moving target due to a wide variety of exemptions and exemption > expiration dates – such as this example: > > > > > > 6(c) Copper alloy containing up to 4 % lead by weight > > Expires on: > > — 21 July 2021 for categories 1-7 and 10, > > — 21 July 2021 for categories 8 and 9 other than *in vitro* diagnostic > medical devices and industrial monitoring and control instruments, > > — 21 July 2023 for category 8 *in vitro* diagnostic medical devices, > > — 21 July 2024 for category 9 industrial monitoring and control > instruments, and for category 11. > > > > By declaring compliance to RoHS you are automatically declaring compliance > with all applicable amending Delegated Directives – none of these, > including 2015/863, amended Annex VI which tells you how to declare > compliance with RoHS: > > > > *The object of the declaration described above is in conformity with > Directive 2011/65/EU of the European Parliament and of the Council of 8 > June 2011 on the restriction of the use of certain hazardous substances in > electrical and electronic equipment* > > > > *@Scott Douglas * > > I presume the complaints were from customers and not market enforcement? > > > > Best regards > > Charlie > > > > *Charlie Blackham* > > *Sulis Consultants Ltd* > > *Tel: +44 (0)7946 624317* > > *Web: https://sulisconsultants.com/ <https://sulisconsultants.com/> * > > Registered in England and Wales, number 05466247 > > > > *From:* Brian Kunde <[email protected]> > *Sent:* 22 November 2020 05:26 > *To:* [email protected] > *Subject:* Re: [PSES] ROHS and DoC > > > > Because we provide DoCs translated into over 30 languages, we try to avoid > text that has to be translated. Our type of products do not have to comply > with these new regulations until next year, but when we do, we plan to use > the same nomenclature that is used for the amendments of Standards by using > the Plus Sign (+). So under the RoHS Directive, we plan to list it like > this: > > > > 2011/65/EU + 2015/863 > > > > Does anyone see any issue with this? > > > > Regards, > > The Other Brian > > > > > > > > On Sat, Nov 21, 2020 at 4:26 PM Scott Douglas <[email protected]> > wrote: > > I used to get complaints I was not up to date when I said 2011/65/EU as > amended. Now I say 2011/65/EU as amended by 2015/863. No more complaints. > > > > > > On Sat, Nov 21, 2020, 12:57 PM Charlie Blackham < > [email protected]> wrote: > > Amund > > Whilst 2015/863 updates 2011/65/EU, you do not CE mark to it. > The DoC must be to 2011/65/EU > > Some people concentrate a lot on 2015/863 but there have been far more > Delegated Directives dealing with exemptions than just this one dealing > with substances ( > https://ec.europa.eu/environment/waste/rohs_eee/legis_en.htm) > > Best regards > Charlie > > Charlie Blackham > Sulis Consultants Ltd > Tel: +44 (0)7946 624317 > Web: https://sulisconsultants.com/ > Registered in England and Wales, number 05466247 > > -----Original Message----- > From: Amund Westin <[email protected]> > Sent: 21 November 2020 10:01 > To: [email protected] > Subject: [PSES] ROHS and DoC > > For EU compliance, I assume Directive 2011/65/EU is still the correct > reference to use? > I see several parties who is referring to 2015/863 in their DoC, but isn't > that reference just a replacement for Annex II in 2011/65/EU? > > Best regards > Amund > > - > ---------------------------------------------------------------- > 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://www.ieee-pses.org/list.html (including how to > unsubscribe) 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://www.ieee-pses.org/list.html (including how to > unsubscribe) > 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://www.ieee-pses.org/list.html (including how to > unsubscribe) <http://www.ieee-pses.org/list.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://www.ieee-pses.org/list.html (including how to > unsubscribe) <http://www.ieee-pses.org/list.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://www.ieee-pses.org/list.html (including how to > unsubscribe) <http://www.ieee-pses.org/list.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://www.ieee-pses.org/list.html (including how to unsubscribe) 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]>
