[PSES] UK WEEE compliance and 2012/19/EU WEEE Directive

[cgittens]

Hello,
 Is it appropriate to use the 2012/19 EU WEEE compliance report for
the UK WEEE compliance requirement?
Thanks
Cecil

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[PSES] WEEE Directive - user information

[Nick Williams]

Article 14 of the new WEEE Directive requires manufacturers to provide 
information to product users on the process and benefits of dealing with WEEE 
in accordance with the Directive (as opposed to just thowing it away with other 
household waste). 

This requirement is not new - it was previously contained in article 10 of the 
old WEEE Directive. 

The Directive gives Member States freedom to decide how to require 
manufacturers to deliver this information and UK government guidance on the 
Directive makes it clear that providing a web link to the information in the 
user instructions, with the bulk of the information accessible via the web 
link, is an acceptable solution. 

I’d be very interested to hear what the Group’s experience of the requirements 
of other Member States is in this regard. 

Thanks

Nick. 

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[PSES] WEEE Directive Compliance for Small Operators

[Carl Newton]

Group,
 
I'm working with a startup that will import ITE into the EU.  They market
entirely via the internet so they have no distribution there.  They've
received a quote from one of the large well-known WEEED compliance
organizations, but it exceeds 12K euros/year and they expect to sell less
than 2 kg of WEEE into the entire EU within in 2014.  This cost is
unmanageable for this small startup at this point.  Do any of you have
experience in satisfying WEEED compliance responsibilities for very small
organizations with no presence within the EU?  Please feel free to contact
me privately if you can help.
 
Thanks very much,
 
Carl

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Re: WEEE Directive

[owner-emc-p...@listserv.ieee.org]

richhug...@aol.com wrote (in <9b.5cd86319.2f843...@aol.com>) about 'WEEE
Directive', on Tue, 5 Apr 2005:
>As interesting one this:
>
>- it is the Commission that propose (and in reality largely draft) EC
Directives in the first place.

Yes, but the two groups of politicians both arranged for their
posteriors to be protected. The Commission drafts Directives but the
Council of Ministers approves them, so shares the responsibility for any
that prove unworkable. And the third group, the Parliament, amends
drafts, so it, too, shares any blame.
>
>- it is the Commission that take Member States to task when they fail to
impliment Directives by the due date.
>
>When one Member State fails to implement a Directive then that MS looks to be
acting in a tardy way. But when multiple MSs fail to implement
>the same Directive then that draws into question as to whether the Directive
was really thought through before it was published in the OJEC.
>So who drafted the legislation in the first place and who decides whether to
prosecute

Is it surprising that some people think the whole thing is a nonsense?
--
Regards, John Woodgate, OOO - Own Opinions Only.
There are two sides to every question, except
'What is a Moebius strip?'
http://www.jmwa.demon.co.uk Also see http://www.isce.org.uk


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Re: WEEE Directive

[owner-emc-p...@listserv.ieee.org]

In a message dated 04/04/2005 18:59:44 GMT Standard Time, j...@jmwa.demon.co.uk
writes:

In theory, the Commission can take an errant government to the European 
Court, and it does happen in practice. But often, the Commission accepts 
that the deviation is justified or inevitable.
-- 

John,
 
As interesting one this:
 
- it is the Commission that propose (and in reality largely draft) EC
Directives in the first place.
 
- it is the Commission that take Member States to task when they fail to
impliment Directives by the due date.
 
When one Member State fails to implement a Directive then that MS looks to be
acting in a tardy way. But when multiple MSs fail to implement the same
Directive then that draws into question as to whether the Directive was really
thought through before it was published in the OJEC.  So who drafted the
legislation in the first place and who decides whether to prosecute?
 
Just a thought
 
Richard Hughes
 
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Re: WEEE Directive

[owner-emc-p...@listserv.ieee.org]

"POWELL, DOUG"  wrote (in
<970a8fe5db2be64eb6eab84087dcc1c8496...@bssexc01.aei.com>) about 'WEEE
Directive', on Mon, 4 Apr 2005:
>How can a single nationality delay beyond the mandated dates published
>for the community?

In theory, the Commission can take an errant government to the European
Court, and it does happen in practice. But often, the Commission accepts
that the deviation is justified or inevitable.
--
Regards, John Woodgate, OOO - Own Opinions Only.
There are two sides to every question, except
'What is a Moebius strip?'
http://www.jmwa.demon.co.uk Also see http://www.isce.org.uk


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RE: WEEE Directive

[owner-emc-p...@listserv.ieee.org]

hello Doug,
that is on my mind as well, I have recieved very good replies,but still unsure
of the EU stance in general ( As One Voice) governing all of the EU.
I realize some countries are trying harder and consious of waste as I am. But
when a directive is released by the EU, it should
be carried out by everyone and not have targets and dates from each EU member,
when there are 25 memebrs and growing.
The confusion of this directive has hit EU countries, thus they are pushing
the dates out to 2006 as noted recently
on emails within this forum, the impact to those countries is felt, so
hopefully they'll know the impact to us as producers exporting
to some EU member states. And knowing all the details is very critical at this
time.
 
regards
Richard,


From: owner-emc-p...@listserv.ieee.org 
mailto:owner-emc-p...@listserv.ieee.org]On Behalf Of POWELL, DOUG
Sent: Monday, April 04, 2005 12:19 PM
To: richhug...@aol.com; charles.gra...@echostar.com; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: WEEE Directive



Richard,

 

You are correct that, at least in this case, much of this is written in fudge.

 

On this side of the pond, to many producers it appears that the UK has the
timeliest information and many are taking this as the norm for the entire
community.  In addition, I don’t have the resources to track every member of
the EU and their implementation dates.  So my policy has been to use the EU
deadlines, as they are published.

 

Last Friday, there is an interesting article from the BBC.  In this article
both the UK and Germany are apparently delaying. My question is this, “How
can a single nationality delay beyond the mandated dates published for the
community? “

 

http://news.bbc.co.uk/2/hi/science/nature/4393347.stm

 

 

Regards,

 

-Doug

Fort Collins, Colorado USA

 

 

 


  _  


From: richhug...@aol.com [mailto:richhug...@aol.com] 
Sent: Friday, April 01, 2005 3:58 PM
To: POWELL, DOUG; charles.gra...@echostar.com; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: WEEE Diective

 

Doug,

 

I'm not sure why you would expect a statement regarding the UK situation on
the Europa web site.

 

I agree that it is always a good idea to look at the source rather than
relying on info 3rd hand, and since the details of the DTI's web site have
already been posted there is no reason why you and others should not do this.

 

Perhaps you and/or others are thinking that the announcement refers to what is
happening in Europe generally - it doesn't, it relates only to the way the UK
Government is approximating the WEEE (and RoHS) Directives into UK law.  Some
other Member States have already enacted the WEE Directive while others are in
the process of doing so.  As far as companies are concerned, EC Directives
should be taken as pointers to what national legislation SHOULD look like. 
Directives direct Member States (e.g. national governments) to pass national
laws, they do not direct private companies to do anything.

 

Directives contain a date by which Member States "must" pass national
legislation to place into force the requirements of the Directive.  Sometimes
Member States don't comply with this date and sometimes the Commission them
prosecute as a result.

 

If you read the DTI announcement then you will see that far from being written
in stone, it is written in fudge.  Enjoy!

 

Richard Hughes

 This message
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RE: WEEE Directive

[owner-emc-p...@listserv.ieee.org]

This is a multi-part message in MIME format.
Richard,

 

You are correct that, at least in this case, much of this is written in fudge.

 

On this side of the pond, to many producers it appears that the UK has the
timeliest information and many are taking this as the norm for the entire
community.  In addition, I don’t have the resources to track every member of
the EU and their implementation dates.  So my policy has been to use the EU
deadlines, as they are published.

 

Last Friday, there is an interesting article from the BBC.  In this article
both the UK and Germany are apparently delaying. My question is this, “How
can a single nationality delay beyond the mandated dates published for the
community? “

 

http://news.bbc.co.uk/2/hi/science/nature/4393347.stm

 

 

Regards,

 

-Doug

Fort Collins, Colorado USA

 

 

 

  _  

From: richhug...@aol.com [mailto:richhug...@aol.com] 
Sent: Friday, April 01, 2005 3:58 PM
To: POWELL, DOUG; charles.gra...@echostar.com; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: WEEE Diective

 

Doug,

 

I'm not sure why you would expect a statement regarding the UK situation on
the Europa web site.

 

I agree that it is always a good idea to look at the source rather than
relying on info 3rd hand, and since the details of the DTI's web site have
already been posted there is no reason why you and others should not do this.

 

Perhaps you and/or others are thinking that the announcement refers to what is
happening in Europe generally - it doesn't, it relates only to the way the UK
Government is approximating the WEEE (and RoHS) Directives into UK law.  Some
other Member States have already enacted the WEE Directive while others are in
the process of doing so.  As far as companies are concerned, EC Directives
should be taken as pointers to what national legislation SHOULD look like. 
Directives direct Member States (e.g. national governments) to pass national
laws, they do not direct private companies to do anything.

 

Directives contain a date by which Member States "must" pass national
legislation to place into force the requirements of the Directive.  Sometimes
Member States don't comply with this date and sometimes the Commission them
prosecute as a result.

 

If you read the DTI announcement then you will see that far from being written
in stone, it is written in fudge.  Enjoy!

 

Richard Hughes










Richard,

 

You are correct that, at least in this
case, much of this is written in fudge.

 

On this side of the pond, to many producers
it appears that the UK
has the timeliest information and many are taking this as the norm for the
entire community.  In addition, I don’t have the resources to track
every member of the EU and their implementation dates.  So my policy has
been to use the EU deadlines, as they are published.

 

Last Friday, there is an interesting article
>from the BBC.  In this article both the UK
and Germany
are apparently delaying. My question is this, “How can a single nationality
delay beyond the mandated dates published for the community? “

 

http://news.bbc.co.uk/2/hi/science/nature/4393347.stm

 

 

Regards,

 

-Doug

Fort Collins, Colorado USA

 

 

 









From:
richhug...@aol.com [mailto:richhug...@aol.com] 
Sent: Friday, April 01, 2005 3:58
PM
To: POWELL, DOUG;
charles.gra...@echostar.com; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: WEEE Diective



 



Doug,





 





I'm not sure why you would expect a
statement regarding the UK
situation on the Europa web site.





 





I agree that it is always a good idea to
look at the source rather than relying on info 3rd hand, and since the details
of the DTI's web site have already been posted there is no reason why you and
others should not do this.





 





Perhaps you and/or others are thinking
that the announcement refers to what is happening in Europe generally - it
doesn't, it relates only to the way the UK Government is approximating the WEEE
(and RoHS) Directives into UK
law.  Some other Member States have already enacted the WEE Directive
while others are in the process of doing so.  As far as companies are
concerned, EC Directives should be taken as pointers to what national
legislation SHOULD look like.  Directives direct Member States (e.g.
national governments) to pass national laws, they do not direct private
companies to do anything.





 





Directives contain a date by which Member
States "must" pass national legislation to place into force the
requirements of the Directive.  Sometimes Member States don't comply with
this date and sometimes the Commission them prosecute as a result.





 





If you read the DTI announcement then you
will see that far from being written in stone, it is written in fudge. 
Enjoy!





 





Richard Hughes












ATT392815.txt
Description: Binary data

RE: WEEE Directive

[owner-emc-p...@listserv.ieee.org]

here in this letter
http://www.dti.gov.uk/sustainability/weee/Planning_for_Implementation.pdf

also see
http://www.dti.gov.uk/sustainability/weee

the Mecca for UK RoHS and WEEE info

-Original Message-
From: owner-emc-p...@listserv.ieee.org on behalf of 
don_macart...@selinc.com
Sent: Fri 01/04/2005 15:50
To: Alan E Hutley Nutwood UK
Cc: Emc-Pstc Discussion Group; owner-emc-p...@listserv.ieee.org
Subject: Re: WEEE Directive



Dear Alan,

Thank you for the information.  Can you please tell us where this
information is published?

Best Regards,

Don MacArthur
Compliance Engineer, NCE, NCT, CIT
Schweitzer Engineering Laboratories, Inc.
2350 NE Hopkins Court
Pullman, WA 99163
PH: (509)334-4934
FAX:  (509)336-4430



 "Alan E Hutley
 Nutwood UK"
  "Emc-Pstc Discussion Group"
 Sent by:  
 owner-emc-pstc@LI  
cc
 STSERV.IEEE.ORG
   
Subject
   WEEE Diective
 04/01/05 12:10 AM


 Please respond to
  "Alan E Hutley
Nutwood UK"
 






Hi All

Under pressure from Industry the UK Government has phased back
    implementation of the WEEE Directive from August until January 2006.

Cheers
Alan E Hutley
Editor
The EMC Journal
www.compliance-club.com

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Re: WEEE Directive

[owner-emc-p...@listserv.ieee.org]

Dear Alan,

Thank you for the information.  Can you please tell us where this
information is published?

Best Regards,

Don MacArthur
Compliance Engineer, NCE, NCT, CIT
Schweitzer Engineering Laboratories, Inc.
2350 NE Hopkins Court
Pullman, WA 99163
PH: (509)334-4934
FAX:  (509)336-4430



 "Alan E Hutley
 Nutwood UK"
  "Emc-Pstc Discussion Group"
 Sent by:  
 owner-emc-pstc@LI  cc
 STSERV.IEEE.ORG
   Subject
   WEEE Diective
 04/01/05 12:10 AM


 Please respond to
  "Alan E Hutley
Nutwood UK"
 






Hi All

Under pressure from Industry the UK Government has phased back
implementation of the WEEE Directive from August until January 2006.

Cheers
Alan E Hutley
Editor
The EMC Journal
www.compliance-club.com

 This
message is from the IEEE Product Safety Engineering Society emc-pstc
discussion list. Website: http://www.ieee-pses.org/


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RE: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

I think you are taking the WEEE.

Regards,
Chris


From: owner-emc-p...@listserv.ieee.org
[mailto:owner-emc-p...@listserv.ieee.org] On Behalf Of Peter L. Tarver
Sent: 01 March 2005 18:12
To: emc-p...@ieee.org
Subject: RE: RoHS / WEEE Directive Questions

It seems clear that the point(s) of these Directive is being
missed.  We all must learn to design products using obsidian
and sticks, provided the obsidian has been assayed (by
instruments similarly created using obsidian and sticks) and
contains no hazardous substances (real or perceived) and the
sticks have not been removed from a living organism.

Those nations possessing volcanoes and large forested tracts
will be the economic winners.


<|8O


Regards,

Peter L. Tarver, PE
ptar...@ieee.org
the facetious one


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 Jim Bacher: j.bac...@ieee.org

All emc-pstc postings are archived and searchable on the web at:

http://www.ieeecommunities.org/emc-pstc

RE: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

The use of sticks will probably be disallowed after it is realized that the
sublimation of wood releases the "greenhouse" gas Carbon Dioxide...

luck,
Brian


 > -Original Message-
 > From: owner-emc-p...@listserv.ieee.org
 > [mailto:owner-emc-p...@listserv.ieee.org]On Behalf Of Peter L. Tarver
 > Sent: Tuesday, March 01, 2005 10:12 AM
 > To: emc-p...@ieee.org
 > Subject: RE: RoHS / WEEE Directive Questions
 >
 >
 > It seems clear that the point(s) of these Directive is being
 > missed.  We all must learn to design products using obsidian
 > and sticks, provided the obsidian has been assayed (by
 > instruments similarly created using obsidian and sticks) and
 > contains no hazardous substances (real or perceived) and the
 > sticks have not been removed from a living organism.
 >
 > Those nations possessing volcanoes and large forested tracts
 > will be the economic winners.
 >
 >
 > <|8O
 >
 >
 > Regards,
 >
 > Peter L. Tarver, PE
 > ptar...@ieee.org
 > the facetious one


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RE: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

It seems clear that the point(s) of these Directive is being
missed.  We all must learn to design products using obsidian
and sticks, provided the obsidian has been assayed (by
instruments similarly created using obsidian and sticks) and
contains no hazardous substances (real or perceived) and the
sticks have not been removed from a living organism.

Those nations possessing volcanoes and large forested tracts
will be the economic winners.


<|8O


Regards,

Peter L. Tarver, PE
ptar...@ieee.org
the facetious one


This message is from the IEEE Product Safety Engineering Society
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RE: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

As usual, I got my answers quickly, and some interesting and insightful
discussion as well, so thanks everyone, and good luck with this.  It's
only going become more fun as the deadlines get closer!

Jim Eichner, P.Eng. 
Compliance Engineering Manager
Xantrex Technology Inc. 
e-mail: jim.eich...@xantrex.com 
web: www.xantrex.com 

Any opinions expressed are those of my invisible friend.

Confidentiality Notice: This email message, including any attachments,
is for the sole use of the intended recipient(s) and may contain
confidential and privileged information. Any unauthorized review, use,
disclosure or distribution is prohibited. If you are not the intended
recipient, please contact the sender by reply e-mail and destroy all
copies of the original message.





From: owner-emc-p...@listserv.ieee.org
[mailto:owner-emc-p...@listserv.ieee.org] On Behalf Of James, Chris
Sent: Monday, February 28, 2005 3:29 AM
To: John Woodgate; emc-p...@ieee.org
Subject: RE: RoHS / WEEE Directive Questions

Yes indeedy - right again, assuming the part does not have an exemption
on it.

The leadframe in its own right must be compliant The encapsulant in its
own right must be compliant Etc, etc, etc,

And then the whole thing has to survive the elevated process temps too.

And remember - lead free does not mean RoHS compliant.

Regards,
Chris


From: owner-emc-p...@listserv.ieee.org
[mailto:owner-emc-p...@listserv.ieee.org] On Behalf Of John Woodgate
Sent: 28 February 2005 10:57
To: emc-p...@ieee.org
Subject: Re: RoHS / WEEE Directive Questions

In article ,
david.cole...@racalinstrumentsgroup.co.uk writes

>32. A semi-conductor package (as a final example) would contain many 
>homogeneous materials, which include the plastic moulding material, the

>tin electroplating coatings on the lead frame, the lead frame alloy and

>the gold bonding wires.

Right. So if there is a little too much lead in the plating on the lead
frame of one IC, the whole product, weighing 10 times as much as the
lead frame, is non-compliant?
--
Regards, John Woodgate, OOO - Own Opinions Only.
The good news is that nothing is compulsory.
The bad news is that everything is prohibited.
http://www.jmwa.demon.co.uk Also see http://www.isce.org.uk


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RE: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

There is no indication the Commission will delay anything - both these
directives have been delayed already. It is now down to individual EU
states to put the legislation in place in time or otherwise at
government level face the consequences.

I today emailed the director of the DTi and the MP who is in part
responsible for the DTi for an update on the UK government position. We
will see if either reply :)


The report is a report on other countries positions not the UK. The UK
commissioned the report and I guess believe the DTi have sufficient info
on their site to show where the UK is at.


Regards,
Chris



From: Ron Pickard [mailto:rpick...@hypercom.com]
Sent: 28 February 2005 16:55
To: James, Chris
Cc: emc-p...@ieee.org
Subject: RE: RoHS / WEEE Directive Questions





Hi Chris,

Finally, someone to address my question.

The Perchards report describes the bulk of the EU countries are still in
various stages of preparing
legislation for the WEEE Directive (this was to have been completed by
13-Aug-2004 according to the
WEED). Given this, is the Commission considering delaying the mandatory
implementation date of this
directive?

Also, aside from a brief sentence on page 2 from the report, I found the
UK to be suspiciously
absent from the report. Are you aware of any reason(s) why? Just
curious.

Best regards,

Ron Pickard
rpick...@hypercom.com





 c...@dolby.co.uk



 02/28/2005 02:53 AM
To
 rpick...@hypercom.com,
jrbar...@iglou.com

cc
 emc-p...@ieee.org,
jim.eich...@xantrex.com

Subject
 RE: RoHS / WEEE
Directive Questions
















In the UK we still await the legislation which will tell us about the
NCH - the UK legislation is
late and being pragmatic we don't actually now expect to see it in time
for Aug 2005.

For other countries you'll need to check out one by one - the Jan 2005
Perchards report on the DTi
website may help you.

Regards,
Chris

From: owner-emc-p...@listserv.ieee.org
[mailto:owner-emc-p...@listserv.ieee.org] On Behalf Of Ron
Pickard
Sent: 25 February 2005 14:30
To: jrbar...@iglou.com
Cc: emc-p...@ieee.org; jim.eich...@xantrex.com
Subject: Re: RoHS / WEEE Directive Questions

And further to that, how and where does one register as required in the
WEEE Directive? A central
organization (national clearing house) was supposed to have been created
for this purpose, but I can
find no evidence that it even exists. Are there any forms to be filled
out?

Regards,

Ron Pickard
rpick...@hypercom.com


To: emc-p...@ieee.org, jim.eich...@xantrex.com
From: jrbar...@iglou.com
Sent by: owner-emc-p...@ieee.org
List-Post: emc-pstc@listserv.ieee.org
Date: 02/24/2005 07:13PM
Subject: Re: RoHS / WEEE Directive Questions

Jim Eichner wrote:
> I have a few questions regarding these Directives...
>
> 1. Does anyone know if the EU has published substance limits yet for
> the RoHS Directive, or if they have decided to adopt the UK limits
> (0.01% for Cadmium, 0.1% for the other 5 substances)?
>
> 2. Are (or will) the limits be "per homogeneous material" as many
> people expect, or will they be per product (the loophole to end all
> loopholes)?
>
> 3. Can anyone point me to the formally published national legislation
> from each country, transposing the WEEE Directive to law?  How about
> pointing me to even ONE !?!

Jim,
Your questions #1 and #2 were discussed on the LEADFREE forum last week
(subscribe at
  http://listserv.ipc.org/scripts/wa.exe?SUBED1=leadfree&A=1  )

Council Decision COM(2004) 606 (
  http://europa.eu.int/eur-lex/en/com/pdf/2004/com2004_0606en01.pdf  )
amends the Annex of the RoHS Directive to permit not-otherwise-exempted
homogeneous materials to contain a maximum of:
* 0.1% lead by weight.
* 0.1% mercury by weight.
* 0.01% cadmium by weight.
* 0.1% hexavalent chromium by weight.
* 0.1% polybrominated biphenyls by weight.
* 0.1% polybrominated diphenyl ethers by weight.

There were several postings that said that this decision has passed the
date where member states could fight it, so it is a done deal.  Several
other postings said that it hasn't been published in the Official
Journal of the European Union (OJ) yet, so it still isn't "official".
Either way, they agreed that these will be the limits for all of the
countries in the European Union, and not just for the United Kingdom.

For your question #3, the United Kingdom's draft law for the RoHS
Directive is at
  http://www.dti.gov.uk/sustainability/weee/RoHs_Regs_draft.pdf

For information on how the various member states are transposing the
RoHS Directive and the WEEE Directive to national laws, see the January
2005 Perchards Report, "Transposition of the WEEE Directive in Other EU
Member States: January 2005," at
  http://www.dti.gov.uk/sustainability/weee/
  

RE: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

Hi Chris,

Finally, someone to address my question.

The Perchards report describes the bulk of the EU countries are still in 
various stages of preparing
legislation for the WEEE Directive (this was to have been completed by 
13-Aug-2004 according to the
WEED). Given this, is the Commission considering delaying the mandatory 
implementation date of this
directive?

Also, aside from a brief sentence on page 2 from the report, I found the UK to 
be suspiciously
absent from the report. Are you aware of any reason(s) why? Just curious.

Best regards,

Ron Pickard
rpick...@hypercom.com




 c...@dolby.co.uk

 02/28/2005 02:53 AM
 To
 rpick...@hypercom.com, 
jrbar...@iglou.com

 cc
 emc-p...@ieee.org, 
jim.eich...@xantrex.com

Subject
 RE: RoHS / WEEE Directive 
Questions










In the UK we still await the legislation which will tell us about the NCH – the 
UK legislation is
late and being pragmatic we don’t actually now expect to see it in time for Aug 
2005.

For other countries you’ll need to check out one by one – the Jan 2005 
Perchards report on the DTi
website may help you.

Regards,
Chris

From: owner-emc-p...@listserv.ieee.org 
[mailto:owner-emc-p...@listserv.ieee.org] On Behalf Of Ron
Pickard
Sent: 25 February 2005 14:30
To: jrbar...@iglou.com
Cc: emc-p...@ieee.org; jim.eich...@xantrex.com
Subject: Re: RoHS / WEEE Directive Questions

And further to that, how and where does one register as required in the WEEE 
Directive? A central
organization (national clearing house) was supposed to have been created for 
this purpose, but I can
find no evidence that it even exists. Are there any forms to be filled out?

Regards,

Ron Pickard
rpick...@hypercom.com


To: emc-p...@ieee.org, jim.eich...@xantrex.com
From: jrbar...@iglou.com
Sent by: owner-emc-p...@ieee.org
List-Post: emc-pstc@listserv.ieee.org
Date: 02/24/2005 07:13PM
Subject: Re: RoHS / WEEE Directive Questions

Jim Eichner wrote:
> I have a few questions regarding these Directives...
>
> 1. Does anyone know if the EU has published substance limits yet for
> the RoHS Directive, or if they have decided to adopt the UK limits
> (0.01% for Cadmium, 0.1% for the other 5 substances)?
>
> 2. Are (or will) the limits be "per homogeneous material" as many
> people expect, or will they be per product (the loophole to end all
> loopholes)?
>
> 3. Can anyone point me to the formally published national legislation
> from each country, transposing the WEEE Directive to law?  How about
> pointing me to even ONE !?!

Jim,
Your questions #1 and #2 were discussed on the LEADFREE forum last week
(subscribe at
  http://listserv.ipc.org/scripts/wa.exe?SUBED1=leadfree&A=1  )

Council Decision COM(2004) 606 (
  http://europa.eu.int/eur-lex/en/com/pdf/2004/com2004_0606en01.pdf  )
amends the Annex of the RoHS Directive to permit not-otherwise-exempted
homogeneous materials to contain a maximum of:
* 0.1% lead by weight.
* 0.1% mercury by weight.
* 0.01% cadmium by weight.
* 0.1% hexavalent chromium by weight.
* 0.1% polybrominated biphenyls by weight.
* 0.1% polybrominated diphenyl ethers by weight.

There were several postings that said that this decision has passed the
date where member states could fight it, so it is a done deal.  Several
other postings said that it hasn't been published in the Official
Journal of the European Union (OJ) yet, so it still isn't "official".
Either way, they agreed that these will be the limits for all of the
countries in the European Union, and not just for the United Kingdom.

For your question #3, the United Kingdom's draft law for the RoHS
Directive is at
  http://www.dti.gov.uk/sustainability/weee/RoHs_Regs_draft.pdf

For information on how the various member states are transposing the
RoHS Directive and the WEEE Directive to national laws, see the January
2005 Perchards Report, "Transposition of the WEEE Directive in Other EU
Member States: January 2005," at
  http://www.dti.gov.uk/sustainability/weee/
  Perchards_Report_January2005.pdf

I have a massive bibliography (69 pages, references to over 1100 source
documents, over 800 links) on designing electronic products to be
lead-free, RoHS-compliant, and WEEE-compliant at
  http://www.dbicorporation.com/rohsbib.htm

My (still under-construction) web page to summarize this data is
  http://www.dbicorporation.com/rohs.htm
It is already 50 pages long, with 5 sections fairly complete, and 15
more sections barely blocked out...  I thought that this would be a
1-month project.  I'

RE: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

I'd like to see anyone trying to separate either mechanically or chemically
pre-soldered and post-soldered plating from a component lead. Once solder
melt is applied to a component pin it dissolves original plating down to
either lead material or a barrier layer and forms a new alloy. And I'm not
even talking here about intermetallic layer - the latter is on a microscopic
scale. Hence you may get initial plating with some amount of lead in it
later dissolved in lead-free solder down to acceptable level.

Best regards,

Alex Gourari



From: James, Chris [mailto:c...@dolby.co.uk]
Sent: Monday, February 28, 2005 6:29 AM
To: John Woodgate; emc-p...@ieee.org
Subject: RE: RoHS / WEEE Directive Questions


Yes indeedy - right again, assuming the part does not have an exemption
on it.

The leadframe in its own right must be compliant
The encapsulant in its own right must be compliant
Etc, etc, etc,

And then the whole thing has to survive the elevated process temps too.

And remember - lead free does not mean RoHS compliant.

Regards,
Chris


From: owner-emc-p...@listserv.ieee.org
[mailto:owner-emc-p...@listserv.ieee.org] On Behalf Of John Woodgate
Sent: 28 February 2005 10:57
To: emc-p...@ieee.org
Subject: Re: RoHS / WEEE Directive Questions

In article ,
david.cole...@racalinstrumentsgroup.co.uk writes

>32. A semi-conductor package (as a final example) would contain many
>homogeneous materials, which include the plastic moulding material, the
>tin electroplating coatings on the lead frame, the lead frame alloy and
>the gold bonding wires.

Right. So if there is a little too much lead in the plating on the lead
frame of one IC, the whole product, weighing 10 times as much as the
lead frame, is non-compliant?
--
Regards, John Woodgate, OOO - Own Opinions Only.
The good news is that nothing is compulsory.
The bad news is that everything is prohibited.
http://www.jmwa.demon.co.uk Also see http://www.isce.org.uk


This message is from the IEEE Product Safety Engineering Society
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For help, send mail to the list administrators:

 Scott Douglas emcp...@ptcnh.net
 Mike Cantwellmcantw...@ieee.org

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 Jim Bacher: j.bac...@ieee.org

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This message is from the IEEE Product Safety Engineering Society
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RE: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

Yes indeedy - right again, assuming the part does not have an exemption
on it.

The leadframe in its own right must be compliant
The encapsulant in its own right must be compliant
Etc, etc, etc,

And then the whole thing has to survive the elevated process temps too.

And remember - lead free does not mean RoHS compliant.

Regards,
Chris


From: owner-emc-p...@listserv.ieee.org
[mailto:owner-emc-p...@listserv.ieee.org] On Behalf Of John Woodgate
Sent: 28 February 2005 10:57
To: emc-p...@ieee.org
Subject: Re: RoHS / WEEE Directive Questions

In article ,
david.cole...@racalinstrumentsgroup.co.uk writes

>32. A semi-conductor package (as a final example) would contain many
>homogeneous materials, which include the plastic moulding material, the
>tin electroplating coatings on the lead frame, the lead frame alloy and
>the gold bonding wires.

Right. So if there is a little too much lead in the plating on the lead
frame of one IC, the whole product, weighing 10 times as much as the
lead frame, is non-compliant?
--
Regards, John Woodgate, OOO - Own Opinions Only.
The good news is that nothing is compulsory.
The bad news is that everything is prohibited.
http://www.jmwa.demon.co.uk Also see http://www.isce.org.uk


This message is from the IEEE Product Safety Engineering Society
emc-pstc discussion list.Website:  http://www.ieee-pses.org/

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For help, send mail to the list administrators:

 Scott Douglas emcp...@ptcnh.net
 Mike Cantwellmcantw...@ieee.org

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 Jim Bacher: j.bac...@ieee.org

All emc-pstc postings are archived and searchable on the web at:

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This message (including any attachments) may contain confidential
information intended for a specific individual and purpose.  If you are not
the intended recipient, delete this message.  If you are not the intended
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RE: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

John,
You are totally correct in your statement below, that it would make the
product non-compliant..

<<"It still appears to be the case that a few micrograms of lead in the
solder on a single SMD component would make a 10 kg piece of gear non-
compliant, which seems bizarre.">>


This is the lunacy of how the directive has evolved. Industry or those
at the coal face of industry were left out the decision making process
far too long.

It is also seems that for many companies the "environmental" compliance
wing has been charged with handling the matter and possibly not always
appreciated the technical issues of the electronics manufacturing
process.

I lived through the intro of LVD and EMC at design and production level
and am now working on both WEEE and RoHS and it is interesting to see
the differing opinions and approaches from these two groups which is now
being highlighted within the EMC/PSTC groups comments on RoHS and
WEEE.

And then there are unbelievably groups within the industry who have
heard nothing about WEEE & RoHS...


Regards,
Chris


From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org] On Behalf
Of John Woodgate
Sent: 28 February 2005 10:31
To: emc-p...@ieee.org
Subject: Re: RoHS / WEEE Directive Questions

In article ,
James, Chris  writes
>Read the guidance John - it does not say chemical separation it says
>mechanical separation.

I was going by the reported UL statement that SMD resistors had to be
dissected into component parts. I don't see how you can separate them
mechanically. I can't even separate the smallest actual resistors
mechanically!

UL may have misinterpreted the requirement, but UL are practised in
interpretation of requirements, so if they have misinterpreted in this
case, my point is made.
>
>While I find even this extreme, if you stop and think why it was done
>this way it was to a) prevent the intentional addition of lead into a
>component

Why would anyone want to do that?

>b) save having to define what constitutes a whole component

'Item of commerce' works pretty well. If you can buy a box/bag/reel of
something, and it doesn't come to pieces without breaking it, that's a
component.

It still appears to be the case that a few micrograms of lead in the
solder on a single SMD component would make a 10 kg piece of gear non-
compliant, which seems bizarre.
--
Regards, John Woodgate, OOO - Own Opinions Only.
The good news is that nothing is compulsory.
The bad news is that everything is prohibited.
http://www.jmwa.demon.co.uk Also see http://www.isce.org.uk


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Re: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

In article ,
david.cole...@racalinstrumentsgroup.co.uk writes

>32. A semi-conductor package (as a final example) would contain many
>homogeneous materials, which include the plastic moulding material, the
>tin electroplating coatings on the lead frame, the lead frame alloy and
>the gold bonding wires.

Right. So if there is a little too much lead in the plating on the lead
frame of one IC, the whole product, weighing 10 times as much as the
lead frame, is non-compliant?
--
Regards, John Woodgate, OOO - Own Opinions Only.
The good news is that nothing is compulsory.
The bad news is that everything is prohibited.
http://www.jmwa.demon.co.uk Also see http://www.isce.org.uk


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RE: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

I would suggest those with an interest in RoHS and WEEE sign up to the very
active IPC LEADFREE email forum so we may keep both topics separate:

 

http://www.ipc.org/contentpage.asp?Pageid=4.3.16

 

 

Regards,

Chris

  _  

From: owner-emc-p...@listserv.ieee.org 
mailto:owner-emc-p...@listserv.ieee.org] On Behalf Of richhug...@aol.com
Sent: 27 February 2005 14:44
To: emc-p...@ieee.org
Subject: Re: RoHS / WEEE Directive Questions

 

Thought 1

 

Understandably, this forum is increasingly discussing environmental matters. 
This will only increase when the draft Energy Using Products Directive is
first published and is then 'approximated' into national law.  When then will
this forum become the EMC, Product Safety and Environmental TC?

 

 

Thought 2

 

The opinions expressed here regarding what the WEED and RoHSD will require are
very onerous.  I have no reason to doubt that the information is not an
accurate repetition of what the correspondents have been told, it's just that
it doesn't seem to make economic sense to me.

 

Products need to be affordable or else people will not purchase them.  

 

In broad terms, the cost of a product can be divided into the cost of turning
raw material into components, the cost of turning components into finished
product, logistic costs related to the movement of components and finished
product, plus profit for the various enterprises in the supply chain.

 

The costs of removing the product from the end customer can be similarly
apportioned.  

 

Who thinks that there will be a significant market for second user components?
 If some recycling facility does manage to remove various components from a
PCB, separate out the resistors of one value and power rating from others {and
ditto for all the other components} will these devices be saleable at a price
comparable with the production of new components?

 

If it is not economically feasible to create a market for second-user
components then perhaps it will be necessary to convert the components into
their elemental constituents.  Again in broad terms, we would have the cost of
turning finished product into components, then turning components into raw
material, plus logistic costs related to collecting the finished product and
transporting the various parts; plus, of course, profit for the various
enterprises in the disposal chain.  Does anyone have an idea of how much this
cost would be as a percentage of the initial production cost?

 

A large percentage of the electrical products sold in Europe are manufactured
wholly or partially in the Far East. I am told that the reason for this is
that the labour cost associated with turning the raw material into finished
goods is lower their than the cost of shipping the product from the place of
manufacture to the place of sale.  Presumably the reverse could also be true? 
In which case Europe could end up shipping its unwanted finished goods to the
Far East for disposal.  Having left the EU, the requirement to recycle rather
than landfill presumably becomes unenforceable in the criminal courts, so we
would be left with civil proceedings if Europe wanted to force the recipient
country to recycle rather than dispose in a less environmentally friendly way.

 

Bottom line, are we talking in terms where the disposal cost is on par with
the production cost?  If yes, I would have thought there would be considerable
political pressure from consumers and companies alike to find an alternative
compromise between doing the absolute best for the environment vs. preventing
Europe from becoming a technological backwater.

 

Or perhaps I'm missing a piece of the jigsaw?  Or does the practical reality
of recycling both today and in the future fall far short of the ideals
expressed by others so far?

 

Regards,

 

Richard Hughes

 This message
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 This

Re: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

In article ,
James, Chris  writes
>Read the guidance John - it does not say chemical separation it says
>mechanical separation.

I was going by the reported UL statement that SMD resistors had to be
dissected into component parts. I don't see how you can separate them
mechanically. I can't even separate the smallest actual resistors
mechanically!

UL may have misinterpreted the requirement, but UL are practised in
interpretation of requirements, so if they have misinterpreted in this
case, my point is made.
>
>While I find even this extreme, if you stop and think why it was done
>this way it was to a) prevent the intentional addition of lead into a
>component

Why would anyone want to do that?

>b) save having to define what constitutes a whole component

'Item of commerce' works pretty well. If you can buy a box/bag/reel of
something, and it doesn't come to pieces without breaking it, that's a
component.

It still appears to be the case that a few micrograms of lead in the
solder on a single SMD component would make a 10 kg piece of gear non-
compliant, which seems bizarre.
--
Regards, John Woodgate, OOO - Own Opinions Only.
The good news is that nothing is compulsory.
The bad news is that everything is prohibited.
http://www.jmwa.demon.co.uk Also see http://www.isce.org.uk


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RE: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

John,

The UK draft guidance quotes the following:

28. The term 'homogeneous' is understood as "of uniform composition
throughout", so examples of "homogeneous materials" would be individual
types of plastics, ceramics, glass, metals, alloys, paper, board, resins
and coatings.
29. The term "mechanically disjointed" means that the materials can be,
in principle, separated by mechanical actions such as unscrewing,
cutting, crushing, grinding and abrasive processes.
30. Using these interpretations, a plastic cover (for example) would be
a 'homogeneous material' if it consisted exclusively of one type of
plastic that was not coated with or had attached to it (or inside it)
any other kinds of materials. In this case, the maximum concentration
values of the RoHS Regulations would apply to the plastic.
31. On the other hand, an electric cable that consisted of metal wires
surrounded by non-metallic insulation materials would be an example of
something that is not 'homogeneous material' because mechanical
processes could separate the different materials. In this case the
maximum concentration values of the RoHS Regulations would apply to each
of the separated materials individually.
32. A semi-conductor package (as a final example) would contain many
homogeneous materials, which include the plastic moulding material, the
tin electroplating coatings on the lead frame, the lead frame alloy and
the gold bonding wires.

Regards,

Dave C.


From: owner-emc-p...@listserv.ieee.org
[mailto:owner-emc-p...@listserv.ieee.org] On Behalf Of John Woodgate
Sent: 27 February 2005 11:42
To: emc-p...@ieee.org
Subject: Re: RoHS / WEEE Directive Questions


In article , brian_ku...@leco.com writes

>That is not what I'm being told by UL. We just had a mini-seminar from
>UL on this topic and we were told that crushing or grinding assemblies
>together to "make them homogeneous" is NOT what you do. You have to
>separate all parts of all assemblies and break them down as far as you
>can. The example they gave us was even surface mounted resistors you
>have to separate the paint, the metal end caps, and the base material.
>They couldn't tell us if we have to remove the traces from PC boards,
>but that was the impression they gave us.

It is, of course, possible, that UL are giving a correct interpretation,
but if so, 'Brussels madness' has struck again, IMHO. If you carry on
the breakdown 'as far as possible', which implies chemical separation of
substance quantities far too small to handle mechanically, you end up
with extracts which are pure lead, pure cadmium, etc. and thus way
outside the permitted levels, even though these extracts are micrograms
and the original product was several kilograms.

Once again, it seems likely that the words used cannot mean what they
appear to mean. This is not by any means a rare situation, in fact it is
extremely common. The authors of these regulatory texts clearly know
what they mean, but consistently fail to comprehend that the words are
capable of other interpretations, which make sense semantically but not
logically or practicably.
--
Regards, John Woodgate, OOO - Own Opinions Only.
The good news is that nothing is compulsory.
The bad news is that everything is prohibited.
http://www.jmwa.demon.co.uk Also see http://www.isce.org.uk


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This message is 

RE: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

Read the guidance John - it does not say chemical separation it says
mechanical separation.

While I find even this extreme, if you stop and think why it was done
this way it was to a) prevent the intentional addition of lead into a
component
b) save having to define what constitutes a whole component


Regards,
Chris


From: owner-emc-p...@listserv.ieee.org
[mailto:owner-emc-p...@listserv.ieee.org] On Behalf Of John Woodgate
Sent: 27 February 2005 11:42
To: emc-p...@ieee.org
Subject: Re: RoHS / WEEE Directive Questions

In article , brian_ku...@leco.com writes

>That is not what I'm being told by UL. We just had a mini-seminar from
>UL on this topic and we were told that crushing or grinding assemblies
>together to "make them homogeneous" is NOT what you do. You have to
>separate all parts of all assemblies and break them down as far as you
>can. The example they gave us was even surface mounted resistors you
>have to separate the paint, the metal end caps, and the base material.
>They couldn't tell us if we have to remove the traces from PC boards,
>but that was the impression they gave us.

It is, of course, possible, that UL are giving a correct interpretation,
but if so, 'Brussels madness' has struck again, IMHO. If you carry on
the breakdown 'as far as possible', which implies chemical separation of
substance quantities far too small to handle mechanically, you end up
with extracts which are pure lead, pure cadmium, etc. and thus way
outside the permitted levels, even though these extracts are micrograms
and the original product was several kilograms.

Once again, it seems likely that the words used cannot mean what they
appear to mean. This is not by any means a rare situation, in fact it is
extremely common. The authors of these regulatory texts clearly know
what they mean, but consistently fail to comprehend that the words are
capable of other interpretations, which make sense semantically but not
logically or practicably.
--
Regards, John Woodgate, OOO - Own Opinions Only.
The good news is that nothing is compulsory.
The bad news is that everything is prohibited.
http://www.jmwa.demon.co.uk Also see http://www.isce.org.uk


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This message (including any attachments) may contain confidential
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RE: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

In the UK we still await the legislation which will tell us about the NCH –
the UK legislation is late and being pragmatic we don’t actually now expect
to see it in time for Aug 2005. 

 

For other countries you’ll need to check out one by one – the Jan 2005
Perchards report on the DTi website may help you.

 

Regards,

Chris

  _  

From: owner-emc-p...@listserv.ieee.org 
mailto:owner-emc-p...@listserv.ieee.org] On Behalf Of Ron Pickard
Sent: 25 February 2005 14:30
To: jrbar...@iglou.com
Cc: emc-p...@ieee.org; jim.eich...@xantrex.com
Subject: Re: RoHS / WEEE Directive Questions

 

And further to that, how and where does one register as required in the WEEE
Directive? A central organization (national clearing house) was supposed to
have been created for this purpose, but I can find no evidence that it even
exists. Are there any forms to be filled out?

 

Regards,

 

Ron Pickard

rpick...@hypercom.com

 



To: emc-p...@ieee.org, jim.eich...@xantrex.com
From: jrbar...@iglou.com
Sent by: owner-emc-p...@ieee.org
List-Post: emc-pstc@listserv.ieee.org
Date: 02/24/2005 07:13PM
Subject: Re: RoHS / WEEE Directive Questions

Jim Eichner wrote:
> I have a few questions regarding these Directives...
>
> 1. Does anyone know if the EU has published substance limits yet for
> the RoHS Directive, or if they have decided to adopt the UK limits
> (0.01% for Cadmium, 0.1% for the other 5 substances)?
>
> 2. Are (or will) the limits be "per homogeneous material" as many
> people expect, or will they be per product (the loophole to end all
> loopholes)?
>
> 3. Can anyone point me to the formally published national legislation
> from each country, transposing the WEEE Directive to law?  How about
> pointing me to even ONE !?!

Jim,
Your questions #1 and #2 were discussed on the LEADFREE forum last week
(subscribe at
  http://listserv.ipc.org/scripts/wa.exe?SUBED1=leadfree
<http://listserv.ipc.org/scripts/wa.exe?SUBED1=leadfree&A=1> &A=1  )

Council Decision COM(2004) 606 (
  http://europa.eu.int/eur-lex/en/com/pdf/2004/com2004_0606en01.pdf  )
amends the Annex of the RoHS Directive to permit not-otherwise-exempted
homogeneous materials to contain a maximum of:
* 0.1% lead by weight.
* 0.1% mercury by weight.
* 0.01% cadmium by weight.
* 0.1% hexavalent chromium by weight.
* 0.1% polybrominated biphenyls by weight.
* 0.1% polybrominated diphenyl ethers by weight.

There were several postings that said that this decision has passed the
date where member states could fight it, so it is a done deal.  Several
other postings said that it hasn't been published in the Official
Journal of the European Union (OJ) yet, so it still isn't "official".
Either way, they agreed that these will be the limits for all of the
countries in the European Union, and not just for the United Kingdom.

For your question #3, the United Kingdom's draft law for the RoHS
Directive is at
  http://www.dti.gov.uk/sustainability/weee/RoHs_Regs_draft.pdf

For information on how the various member states are transposing the
RoHS Directive and the WEEE Directive to national laws, see the January
2005 Perchards Report, "Transposition of the WEEE Directive in Other EU
Member States: January 2005," at
  http://www.dti.gov.uk/sustainability/weee/
  Perchards_Report_January2005.pdf

I have a massive bibliography (69 pages, references to over 1100 source
documents, over 800 links) on designing electronic products to be
lead-free, RoHS-compliant, and WEEE-compliant at
  http://www.dbicorporation.com/rohsbib.htm

My (still under-construction) web page to summarize this data is
  http://www.dbicorporation.com/rohs.htm
It is already 50 pages long, with 5 sections fairly complete, and 15
more sections barely blocked out...  I thought that this would be a
1-month project.  I've been working on it almost 2 months now, just
gathering the source documents, which already fill one book shelf and
two file-cabinet drawers.

   John Barnes KS4GL, PE, NCE, ESDC Eng, PSE, SM IEEE
   dBi Corporation
http://www.dbicorporation.com/


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 This message
is from the IEEE Product Safe

RE: RE: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

The UL are correct on one point - crushing a PCB into one mass is NOT
what the directive specifies.

However at present there are no practicable methods (for the most) to
test product.


CE marking DOES NOT apply to the RoHS or WEEE directive. WEEE has a
crossed out wheelie bin mark requirement. RoHS has no marking
requirement.



Regards,
Chris


From: owner-emc-p...@listserv.ieee.org
[mailto:owner-emc-p...@listserv.ieee.org] On Behalf Of
brian_ku...@leco.com
Sent: 25 February 2005 15:50
To: alexandre.gour...@cmot.xerox.com; jrbar...@iglou.com;
emc-p...@ieee.org; jim.eich...@xantrex.com
Subject: Re:RE: RoHS / WEEE Directive Questions

John,

That is not what I'm being told by UL. We just had a mini-seminar from
UL on
this topic and we were told that crushing or grinding assemblies
together to
"make them homogeneous" is NOT what you do. You have to separate all
parts of
all assemblies and break them down as far as you can. The example they
gave us
was even surface mounted resistors you have to separate the paint, the
metal end
caps, and the base material. They couldn't tell us if we have to remove
the
traces from PC boards, but that was the impression they gave us.

Is UL giving us a line or is this the way it will be done?

They also said that products currently on the market in Europe did not
have to
meet these directives unless they were changed is some undefined but
fairly
major way. These directives only apply to NEW products being introduced
to the
market. Is this true?

Also, we were told the CE marking applied to these directives. Well, if
you have
CE marked products in the market prior to July 2006 and you do not have
to apply
these directives to existing products, then you can not assume a CE
marked
product meets the RoHS directive. Must request the DOC to find out.

Am I all wet here or are these things what the industry knows to be
true? The
more I hear and read on this topic the more frustrating it gets.

Thanks for any replies.
Brian

Reply Separator
Subject:RE: RoHS / WEEE Directive Questions
Author: alexandre.gour...@cmot.xerox.com
List-Post: emc-pstc@listserv.ieee.org
Date:   2/25/2005 9:20 AM

John,

I had the same set of questions for myself (#1 and #2). Does the way
they
specify the limits to be "per homogeneous material" imply that when some
product (i.e. assembled printed circuit board) is submitted for the
compliance test and turned into "homogeneous material" by either
crushing or
grinding we are all actually left with a loophole allowing some
components
on the board to be non-RoHS compliant as long as the board as a whole
meets
the spec?
Can it be extended to the unit where the board is installed to allow the
banned substance to be even more "diluted"?
Anyone else in the forum knows the answer, any links?

Best regards,

Alex Gourari


From: John Barnes [mailto:jrbar...@iglou.com]
Sent: Thursday, February 24, 2005 9:14 PM
To: emc-p...@ieee.org; Jim Eichner
Subject: Re: RoHS / WEEE Directive Questions


Jim Eichner wrote:
> I have a few questions regarding these Directives...
>
> 1. Does anyone know if the EU has published substance limits yet for
> the RoHS Directive, or if they have decided to adopt the UK limits
> (0.01% for Cadmium, 0.1% for the other 5 substances)?
>
> 2. Are (or will) the limits be "per homogeneous material" as many
> people expect, or will they be per product (the loophole to end all
> loopholes)?
>
> 3. Can anyone point me to the formally published national legislation
> from each country, transposing the WEEE Directive to law?  How about
> pointing me to even ONE !?!

Jim,
Your questions #1 and #2 were discussed on the LEADFREE forum last week
(subscribe at
http://listserv.ipc.org/scripts/wa.exe?SUBED1=leadfree&A=1   )

Council Decision COM(2004) 606 (
http://europa.eu.int/eur-lex/en/com/pdf/2004/com2004_0606en01.pdf   )
amends the Annex of the RoHS Directive to permit not-otherwise-exempted
homogeneous materials to contain a maximum of:
* 0.1% lead by weight.
* 0.1% mercury by weight.
* 0.01% cadmium by weight.
* 0.1% hexavalent chromium by weight.
* 0.1% polybrominated biphenyls by weight.
* 0.1% polybrominated diphenyl ethers by weight.

There were several postings that said that this decision has passed the
date where member states could fight it, so it is a done deal.  Several
other postings said that it hasn't been published in the Official
Journal of the European Union (OJ) yet, so it still isn't "official".
Either way, they agreed that these will be the limits for all of the
countries in the European Union, and not just for the United Kingdom.

For your question #3, the United Kingdom's draft law for the RoHS
Directive is at
http://www.dti.gov.uk/sustainability/weee/RoHs_Regs_draft.pdf

For information on how the various member states are transposing the
RoHS Directive 

Re: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

In article <53.2241c9f3.2f533...@aol.com>, richhug...@aol.com writes

>A large percentage of the electrical products sold in Europe are
>manufactured wholly or partially in the Far East. I am told that the
>reason  for this is that the labour cost associated with turning the raw
>material into  finished goods is lower their than the cost of shipping
>the product from the  place of manufacture to the place of sale.

Well, not quite, but we know what you mean. Cost of production + cost of
transportation to market is lower for the Far East product in spite of
the higher cost of transportation.

>
>Presumably the reverse could  also be true? In which case Europe could
>end up shipping its unwanted  finished goods to the Far East for
>disposal.  Having left the EU, the  requirement to recycle rather than
>landfill presumably becomes unenforceable in  the criminal courts, so we
>would be left with civil proceedings if Europe wanted  to force the
>recipient country to recycle rather than dispose in a less
>environmentally friendly way.

It's already happening. There was an item on one TV channel (maybe not
in UK) about a disused European refrigerator mountain in China. Guess
where the CFCs go!
--
Regards, John Woodgate, OOO - Own Opinions Only.
The good news is that nothing is compulsory.
The bad news is that everything is prohibited.
http://www.jmwa.demon.co.uk Also see http://www.isce.org.uk


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Re: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

Thought 1
 
Understandably, this forum is increasingly discussing environmental matters. 
This will only increase when the draft Energy Using Products Directive is
first published and is then 'approximated' into national law.  When then will
this forum become the EMC, Product Safety and Environmental TC?
 
 
Thought 2
 
The opinions expressed here regarding what the WEED and RoHSD will require are
very onerous.  I have no reason to doubt that the information is not an
accurate repetition of what the correspondents have been told, it's just that
it doesn't seem to make economic sense to me.
 
Products need to be affordable or else people will not purchase them.  
 
In broad terms, the cost of a product can be divided into the cost of turning
raw material into components, the cost of turning components into finished
product, logistic costs related to the movement of components and finished
product, plus profit for the various enterprises in the supply chain.
 
The costs of removing the product from the end customer can be similarly
apportioned.  
 
Who thinks that there will be a significant market for second user components?
 If some recycling facility does manage to remove various components from a
PCB, separate out the resistors of one value and power rating from others {and
ditto for all the other components} will these devices be saleable at a price
comparable with the production of new components?
 
If it is not economically feasible to create a market for second-user
components then perhaps it will be necessary to convert the components into
their elemental constituents.  Again in broad terms, we would have the cost of
turning finished product into components, then turning components into raw
material, plus logistic costs related to collecting the finished product and
transporting the various parts; plus, of course, profit for the various
enterprises in the disposal chain.  Does anyone have an idea of how much this
cost would be as a percentage of the initial production cost?
 
A large percentage of the electrical products sold in Europe are manufactured
wholly or partially in the Far East. I am told that the reason for this is
that the labour cost associated with turning the raw material into finished
goods is lower their than the cost of shipping the product from the place of
manufacture to the place of sale.  Presumably the reverse could also be true? 
In which case Europe could end up shipping its unwanted finished goods to the
Far East for disposal.  Having left the EU, the requirement to recycle rather
than landfill presumably becomes unenforceable in the criminal courts, so we
would be left with civil proceedings if Europe wanted to force the recipient
country to recycle rather than dispose in a less environmentally friendly way.
 
Bottom line, are we talking in terms where the disposal cost is on par with
the production cost?  If yes, I would have thought there would be considerable
political pressure from consumers and companies alike to find an alternative
compromise between doing the absolute best for the environment vs. preventing
Europe from becoming a technological backwater.
 
Or perhaps I'm missing a piece of the jigsaw?  Or does the practical reality
of recycling both today and in the future fall far short of the ideals
expressed by others so far?
 
Regards,
 
Richard Hughes
 This message
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Re: RoHS / WEEE Directive Questions

[owner-emc-p...@ieee.org]

In article , brian_ku...@leco.com writes

>That is not what I'm being told by UL. We just had a mini-seminar from
>UL on this topic and we were told that crushing or grinding assemblies
>together to "make them homogeneous" is NOT what you do. You have to
>separate all parts of all assemblies and break them down as far as you
>can. The example they gave us was even surface mounted resistors you
>have to separate the paint, the metal end caps, and the base material.
>They couldn't tell us if we have to remove the traces from PC boards,
>but that was the impression they gave us.

It is, of course, possible, that UL are giving a correct interpretation,
but if so, 'Brussels madness' has struck again, IMHO. If you carry on
the breakdown 'as far as possible', which implies chemical separation of
substance quantities far too small to handle mechanically, you end up
with extracts which are pure lead, pure cadmium, etc. and thus way
outside the permitted levels, even though these extracts are micrograms
and the original product was several kilograms.

Once again, it seems likely that the words used cannot mean what they
appear to mean. This is not by any means a rare situation, in fact it is
extremely common. The authors of these regulatory texts clearly know
what they mean, but consistently fail to comprehend that the words are
capable of other interpretations, which make sense semantically but not
logically or practicably.
--
Regards, John Woodgate, OOO - Own Opinions Only.
The good news is that nothing is compulsory.
The bad news is that everything is prohibited.
http://www.jmwa.demon.co.uk Also see http://www.isce.org.uk


This message is from the IEEE Product Safety Engineering Society
emc-pstc discussion list.Website:  http://www.ieee-pses.org/

To post a message to the list, send your e-mail to emc-p...@ieee.org

Instructions:  http://listserv.ieee.org/listserv/request/user-guide.html

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For help, send mail to the list administrators:

 Scott Douglas emcp...@ptcnh.net
 Mike Cantwellmcantw...@ieee.org

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 Richard Nute:   ri...@ieee.org
 Jim Bacher: j.bac...@ieee.org

All emc-pstc postings are archived and searchable on the web at:

http://www.ieeecommunities.org/emc-pstc

Re: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

Brian,

Based on the impression left on me at the PSES meeting you are correct.
  It is broken down to the last detail.  For example a wire wound
resistor you would have to break down to even the tinning material on
the lead.  If this fails the system is non-compliant.

Seems awfully extreme to me, but that is what I get from it.

Josh

brian_ku...@leco.com wrote:
> Ok, I see we are talking about two different things. For separating metals
for
> recycling and the WEEE direction, grinding up circuit boards would be an
> acceptable method.
>
> I was referring to the RhHS directive where every part of an assembly has to
be
> broken down to its smallest parts and individually tested. For instance, in
an
> entire PCB assembly, if one part fails the requirement for lead, then the
entire
> unit would be non-compliant. You can't grind up the assembly and dilute the
test
> results. This is what I am being told. Please correct me if I'm wrong.
>
> Thanks,
> Brian
>
> Reply Separator
> Subject:Re: RoHS / WEEE Directive Questions
> Author: wisemanps...@mchsi.com
> Date:   2/25/2005 2:19 PM
>
> David,
>
> I once read an article regarding the grind and heat process.  If I
> recall this was a process used in Holland and once separated some of the
> material was then used for roads and what not, while the lead and other
> heavy metals were placed in some sort if bin never to be touched again.
>
> I will have to see if I can find that article again, it was pretty
> interesting.
>
> Josh
>
> David Heald wrote:
>
>>I think that what you heard is right - separation for recycling or re-use is
mandated under WEEE (but then the techno objects would be 'reuse' unless they
too fall under WEEE?).  Actually,  I've recently heard of a method that grinds
everything and then uses heat to melt it and achieve the separation, so this
would support both accounts.  I'm not sure if the process has been created or
perfected yet, but it seems to be a good idea - and relatively simple.
>>
>>Best Regards,
>>-Dave
>>
>>
>>
>>>>>"Price, Ed"  02/25/05 11:08AM >>>
>>
>>
>>
>>-Original Message-
>>From: brian_ku...@leco.com [mailto:brian_ku...@leco.com]
>>Sent: Friday, February 25, 2005 7:50 AM
>>To: alexandre.gour...@cmot.xerox.com; jrbar...@iglou.com; emc-p...@ieee.org;
>>jim.eich...@xantrex.com
>>Subject: Re:RE: RoHS / WEEE Directive Questions
>>
>>John,
>>
>>That is not what I'm being told by UL. We just had a mini-seminar from UL on
>>this topic and we were told that crushing or grinding assemblies together to
>>"make them homogeneous" is NOT what you do. You have to separate all parts
>>of all assemblies and break them down as far as you can. The example they
>>gave us was even surface mounted resistors you have to separate the paint,
>>the metal end caps, and the base material. They couldn't tell us if we have
>>to remove the traces from PC boards, but that was the impression they gave
>>us.
>>
>>Is UL giving us a line or is this the way it will be done?
>>
>>They also said that products currently on the market in Europe did not have
>>to meet these directives unless they were changed is some undefined but
>>fairly major way. These directives only apply to NEW products being
>>introduced to the market. Is this true?
>>
>>Also, we were told the CE marking applied to these directives. Well, if you
>>have CE marked products in the market prior to July 2006 and you do not have
>>to apply these directives to existing products, then you can not assume a CE
>>marked product meets the RoHS directive. Must request the DOC to find out.
>>
>>Am I all wet here or are these things what the industry knows to be true?
>>The more I hear and read on this topic the more frustrating it gets.
>>
>>Thanks for any replies.
>>Brian
>>
>>
>>
>>I haven't had to face this WEEE question yet, but I wonder if an application
>>of devious thinking can come up with a workable solution (workable that is
>>until they get around to outlawing it)?
>>
>>I wonder if you could take the discarded "assemblies", grind them to powder,
>>and them compress them into a dense, fused cube. These cubes could be then
>>be sold as techno objects de art or garden ornaments, possibly at a deep
>>discount. Instant 100% recycling, with no waste stream! I think I'd like
>>mine electroless nickel plated.
>>
>>Ed
>>
>>Ed Price
>>ed.pr...@cubic.com WB6WSN
>>NARTE Certified 

Re[2]: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

Ok, I see we are talking about two different things. For separating metals for
recycling and the WEEE direction, grinding up circuit boards would be an
acceptable method.

I was referring to the RhHS directive where every part of an assembly has to be
broken down to its smallest parts and individually tested. For instance, in an
entire PCB assembly, if one part fails the requirement for lead, then the
entire
unit would be non-compliant. You can't grind up the assembly and dilute the
test
results. This is what I am being told. Please correct me if I'm wrong.

Thanks,
Brian

Reply Separator
Subject:Re: RoHS / WEEE Directive Questions
Author: wisemanps...@mchsi.com
List-Post: emc-pstc@listserv.ieee.org
Date:   2/25/2005 2:19 PM

David,

I once read an article regarding the grind and heat process.  If I
recall this was a process used in Holland and once separated some of the
material was then used for roads and what not, while the lead and other
heavy metals were placed in some sort if bin never to be touched again.

I will have to see if I can find that article again, it was pretty
interesting.

Josh

David Heald wrote:
> I think that what you heard is right - separation for recycling or re-use is
mandated under WEEE (but then the techno objects would be 'reuse' unless they
too fall under WEEE?).  Actually,  I've recently heard of a method that grinds
everything and then uses heat to melt it and achieve the separation, so this
would support both accounts.  I'm not sure if the process has been created or
perfected yet, but it seems to be a good idea - and relatively simple.
>
> Best Regards,
> -Dave
>
>
>>>>"Price, Ed"  02/25/05 11:08AM >>>
>
>
>
> -Original Message-
> From: brian_ku...@leco.com [mailto:brian_ku...@leco.com]
> Sent: Friday, February 25, 2005 7:50 AM
> To: alexandre.gour...@cmot.xerox.com; jrbar...@iglou.com; emc-p...@ieee.org;
> jim.eich...@xantrex.com
> Subject: Re:RE: RoHS / WEEE Directive Questions
>
> John,
>
> That is not what I'm being told by UL. We just had a mini-seminar from UL on
> this topic and we were told that crushing or grinding assemblies together to
> "make them homogeneous" is NOT what you do. You have to separate all parts
> of all assemblies and break them down as far as you can. The example they
> gave us was even surface mounted resistors you have to separate the paint,
> the metal end caps, and the base material. They couldn't tell us if we have
> to remove the traces from PC boards, but that was the impression they gave
> us.
>
> Is UL giving us a line or is this the way it will be done?
>
> They also said that products currently on the market in Europe did not have
> to meet these directives unless they were changed is some undefined but
> fairly major way. These directives only apply to NEW products being
> introduced to the market. Is this true?
>
> Also, we were told the CE marking applied to these directives. Well, if you
> have CE marked products in the market prior to July 2006 and you do not have
> to apply these directives to existing products, then you can not assume a CE
> marked product meets the RoHS directive. Must request the DOC to find out.
>
> Am I all wet here or are these things what the industry knows to be true?
> The more I hear and read on this topic the more frustrating it gets.
>
> Thanks for any replies.
> Brian
>
>
>
> I haven't had to face this WEEE question yet, but I wonder if an application
> of devious thinking can come up with a workable solution (workable that is
> until they get around to outlawing it)?
>
> I wonder if you could take the discarded "assemblies", grind them to powder,
> and them compress them into a dense, fused cube. These cubes could be then
> be sold as techno objects de art or garden ornaments, possibly at a deep
> discount. Instant 100% recycling, with no waste stream! I think I'd like
> mine electroless nickel plated.
>
> Ed
>
> Ed Price
> ed.pr...@cubic.com WB6WSN
> NARTE Certified EMC Engineer & Technician
> Electromagnetic Compatibility Lab
> Cubic Defense Applications
> San Diego, CA USA
> 858-505-2780 (Voice)
> 858-505-1583 (Fax)
> Military & Avionics EMC Is Our Specialty
>
>
>
>
> 
> This message is from the IEEE Product Safety Engineering Society
> emc-pstc discussion list.Website:  http://www.ieee-pses.org/
>
> To post a message to the list, send your e-mail to emc-p...@ieee.org
>
> Instructions:  http://listserv.ieee.org/listserv/request/user-guide.html
>
> List rules: http://www.ieee-pses.org/listrules.html
>
> For help, se

RoHS / WEEE Directive Questions - CE Marking

[owner-emc-p...@listserv.ieee.org]

Group,


Regarding the question about affixing the CE Mark for compliance with the
RoHS and WEEE directives,
my observation on the RoHS/WEEE directives is that they are not listed as
"New Approach Directives", or "(Directives providing for CE Marking)"
according to the European Commission's  site (below)

http://europa.eu.int/comm/enterprise/newapproach/standardization/harmstds/re
flist.html

Moreover, if you look in the body of the New Approach Directives, they
either instruct you or have been amended to instruct you to affix the CE
Mark to "Apparatus complying with all relevant essential requirements".  The
R&TTE directive (1999/5/EC) is a nice example, as are others.

Neither the RoHS Directive (2002/95/EC)
 http://europa.eu.int/smartapi/cgi/sga_doc?smartapi!celexapi!prod!CELEXnumdo
c&lg=EN&numdoc=32002L0095&model=guichett
nor or the WEEE Directive (2002/96 EC)
http://europa.eu.int/smartapi/cgi/sga_doc?smartapi!celexapi!prod!CELEXnumdoc
&lg=EN&numdoc=32002L0096&model=guichett

call for CE Marking.

Best Regards,


Don Gies, N.C.E
Senior Product Compliance Engineer
Lucent Technologies - Bell Labs
Holmdel, NJ 07733 USA









From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf
Of Josh Wiseman
Sent: Friday, February 25, 2005 1:39 PM
To: brian_ku...@leco.com
Cc: alexandre.gour...@cmot.xerox.com; jrbar...@iglou.com;
emc-p...@ieee.org; jim.eich...@xantrex.com
Subject: Re: RoHS / WEEE Directive Questions


Brian,

 From a PSES chapter meeting I attended recently your homogeneous
example is correct.  In this case the info you have received from UL
does correlate with that of some materials experts who are giving brief
seminars on this vary subject.

According to this same meetings speaker the compliance requirement for
new products versus old products is also accurate.  With regards to the
CE mark that is something I know nothing about.

Regards,
Josh

brian_ku...@leco.com wrote:
> John,
>
> That is not what I'm being told by UL. We just had a mini-seminar from UL
on
> this topic and we were told that crushing or grinding assemblies together
to
> "make them homogeneous" is NOT what you do. You have to separate all parts
of
> all assemblies and break them down as far as you can. The example they
gave us
> was even surface mounted resistors you have to separate the paint, the
metal end
> caps, and the base material. They couldn't tell us if we have to remove
the
> traces from PC boards, but that was the impression they gave us.
>
> Is UL giving us a line or is this the way it will be done?
>
> They also said that products currently on the market in Europe did not
have to
> meet these directives unless they were changed is some undefined but
fairly
> major way. These directives only apply to NEW products being introduced to
the
> market. Is this true?
>
> Also, we were told the CE marking applied to these directives. Well, if
you have
> CE marked products in the market prior to July 2006 and you do not have to
apply
> these directives to existing products, then you can not assume a CE marked
> product meets the RoHS directive. Must request the DOC to find out.
>
> Am I all wet here or are these things what the industry knows to be true?
The
> more I hear and read on this topic the more frustrating it gets.
>
> Thanks for any replies.
> Brian
>
> Reply Separator
> Subject:RE: RoHS / WEEE Directive Questions
> Author: alexandre.gour...@cmot.xerox.com
> Date:   2/25/2005 9:20 AM
>
> John,
>
> I had the same set of questions for myself (#1 and #2). Does the way they
> specify the limits to be "per homogeneous material" imply that when some
> product (i.e. assembled printed circuit board) is submitted for the
> compliance test and turned into "homogeneous material" by either crushing
or
> grinding we are all actually left with a loophole allowing some components
> on the board to be non-RoHS compliant as long as the board as a whole
meets
> the spec?
> Can it be extended to the unit where the board is installed to allow the
> banned substance to be even more "diluted"?
> Anyone else in the forum knows the answer, any links?
>
> Best regards,
>
> Alex Gourari
>
> -Original Message-
> From: John Barnes [mailto:jrbar...@iglou.com]
> Sent: Thursday, February 24, 2005 9:14 PM
> To: emc-p...@ieee.org; Jim Eichner
> Subject: Re: RoHS / WEEE Directive Questions
>
>
> Jim Eichner wrote:
>
>>I have a few questions regarding these Directives...
>>
>>1. Does anyone know if the EU has published substance limits yet for
>>the RoHS Directive, or if they have decided to adopt the UK limits
>>(0.01% for Cadmium, 0.1% for the other 5 substances

Re: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

David,

I once read an article regarding the grind and heat process.  If I
recall this was a process used in Holland and once separated some of the
material was then used for roads and what not, while the lead and other
heavy metals were placed in some sort if bin never to be touched again.

I will have to see if I can find that article again, it was pretty
interesting.

Josh

David Heald wrote:
> I think that what you heard is right - separation for recycling or re-use is
mandated under WEEE (but then the techno objects would be 'reuse' unless they
too fall under WEEE?).  Actually,  I've recently heard of a method that grinds
everything and then uses heat to melt it and achieve the separation, so this
would support both accounts.  I'm not sure if the process has been created or
perfected yet, but it seems to be a good idea - and relatively simple.
>
> Best Regards,
> -Dave
>
>
>>>>"Price, Ed"  02/25/05 11:08AM >>>
>
>
>
> -Original Message-
> From: brian_ku...@leco.com [mailto:brian_ku...@leco.com]
> Sent: Friday, February 25, 2005 7:50 AM
> To: alexandre.gour...@cmot.xerox.com; jrbar...@iglou.com; emc-p...@ieee.org;
> jim.eich...@xantrex.com
> Subject: Re:RE: RoHS / WEEE Directive Questions
>
> John,
>
> That is not what I'm being told by UL. We just had a mini-seminar from UL on
> this topic and we were told that crushing or grinding assemblies together to
> "make them homogeneous" is NOT what you do. You have to separate all parts
> of all assemblies and break them down as far as you can. The example they
> gave us was even surface mounted resistors you have to separate the paint,
> the metal end caps, and the base material. They couldn't tell us if we have
> to remove the traces from PC boards, but that was the impression they gave
> us.
>
> Is UL giving us a line or is this the way it will be done?
>
> They also said that products currently on the market in Europe did not have
> to meet these directives unless they were changed is some undefined but
> fairly major way. These directives only apply to NEW products being
> introduced to the market. Is this true?
>
> Also, we were told the CE marking applied to these directives. Well, if you
> have CE marked products in the market prior to July 2006 and you do not have
> to apply these directives to existing products, then you can not assume a CE
> marked product meets the RoHS directive. Must request the DOC to find out.
>
> Am I all wet here or are these things what the industry knows to be true?
> The more I hear and read on this topic the more frustrating it gets.
>
> Thanks for any replies.
> Brian
>
>
>
> I haven't had to face this WEEE question yet, but I wonder if an application
> of devious thinking can come up with a workable solution (workable that is
> until they get around to outlawing it)?
>
> I wonder if you could take the discarded "assemblies", grind them to powder,
> and them compress them into a dense, fused cube. These cubes could be then
> be sold as techno objects de art or garden ornaments, possibly at a deep
> discount. Instant 100% recycling, with no waste stream! I think I'd like
> mine electroless nickel plated.
>
> Ed
>
> Ed Price
> ed.pr...@cubic.com WB6WSN
> NARTE Certified EMC Engineer & Technician
> Electromagnetic Compatibility Lab
> Cubic Defense Applications
> San Diego, CA USA
> 858-505-2780 (Voice)
> 858-505-1583 (Fax)
> Military & Avionics EMC Is Our Specialty
>
>
>
>
> 
> This message is from the IEEE Product Safety Engineering Society
> emc-pstc discussion list.Website:  http://www.ieee-pses.org/
>
> To post a message to the list, send your e-mail to emc-p...@ieee.org
>
> Instructions:  http://listserv.ieee.org/listserv/request/user-guide.html
>
> List rules: http://www.ieee-pses.org/listrules.html
>
> For help, send mail to the list administrators:
>
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>  Mike Cantwellmcantw...@ieee.org
>
> For policy questions, send mail to:
>
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>  Jim Bacher: j.bac...@ieee.org
>
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>
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>
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> 

RE: RE: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

I think that what you heard is right - separation for recycling or re-use is
mandated under WEEE (but then the techno objects would be 'reuse' unless they
too fall under WEEE?).  Actually,  I've recently heard of a method that grinds
everything and then uses heat to melt it and achieve the separation, so this
would support both accounts.  I'm not sure if the process has been created or
perfected yet, but it seems to be a good idea - and relatively simple.

Best Regards,
-Dave

>>> "Price, Ed"  02/25/05 11:08AM >>>



From: brian_ku...@leco.com [mailto:brian_ku...@leco.com]
Sent: Friday, February 25, 2005 7:50 AM
To: alexandre.gour...@cmot.xerox.com; jrbar...@iglou.com; emc-p...@ieee.org;
jim.eich...@xantrex.com
Subject: Re:RE: RoHS / WEEE Directive Questions

John,

That is not what I'm being told by UL. We just had a mini-seminar from UL on
this topic and we were told that crushing or grinding assemblies together to
"make them homogeneous" is NOT what you do. You have to separate all parts
of all assemblies and break them down as far as you can. The example they
gave us was even surface mounted resistors you have to separate the paint,
the metal end caps, and the base material. They couldn't tell us if we have
to remove the traces from PC boards, but that was the impression they gave
us.

Is UL giving us a line or is this the way it will be done?

They also said that products currently on the market in Europe did not have
to meet these directives unless they were changed is some undefined but
fairly major way. These directives only apply to NEW products being
introduced to the market. Is this true?

Also, we were told the CE marking applied to these directives. Well, if you
have CE marked products in the market prior to July 2006 and you do not have
to apply these directives to existing products, then you can not assume a CE
marked product meets the RoHS directive. Must request the DOC to find out.

Am I all wet here or are these things what the industry knows to be true?
The more I hear and read on this topic the more frustrating it gets.

Thanks for any replies.
Brian



I haven't had to face this WEEE question yet, but I wonder if an application
of devious thinking can come up with a workable solution (workable that is
until they get around to outlawing it)?

I wonder if you could take the discarded "assemblies", grind them to powder,
and them compress them into a dense, fused cube. These cubes could be then
be sold as techno objects de art or garden ornaments, possibly at a deep
discount. Instant 100% recycling, with no waste stream! I think I'd like
mine electroless nickel plated.

Ed

Ed Price
ed.pr...@cubic.com WB6WSN
NARTE Certified EMC Engineer & Technician
Electromagnetic Compatibility Lab
Cubic Defense Applications
San Diego, CA USA
858-505-2780 (Voice)
858-505-1583 (Fax)
Military & Avionics EMC Is Our Specialty





This message is from the IEEE Product Safety Engineering Society
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This email has been scanned for computer viruses.



This email has been scanned for computer viruses.


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For help, send mail to the list administrators:

 Scott Douglas emcp...@ptcnh.net
 Mike Cantwellmcantw...@ieee.org

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 Jim Bacher: j.bac...@ieee.org

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Re: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

Brian,

 From a PSES chapter meeting I attended recently your homogeneous
example is correct.  In this case the info you have received from UL
does correlate with that of some materials experts who are giving brief
seminars on this vary subject.

According to this same meetings speaker the compliance requirement for
new products versus old products is also accurate.  With regards to the
CE mark that is something I know nothing about.

Regards,
Josh

brian_ku...@leco.com wrote:
> John,
>
> That is not what I'm being told by UL. We just had a mini-seminar from UL on
> this topic and we were told that crushing or grinding assemblies together to
> "make them homogeneous" is NOT what you do. You have to separate all parts of
> all assemblies and break them down as far as you can. The example they gave
us
> was even surface mounted resistors you have to separate the paint, the metal
end
> caps, and the base material. They couldn't tell us if we have to remove the
> traces from PC boards, but that was the impression they gave us.
>
> Is UL giving us a line or is this the way it will be done?
>
> They also said that products currently on the market in Europe did not have
to
> meet these directives unless they were changed is some undefined but fairly
> major way. These directives only apply to NEW products being introduced to
the
> market. Is this true?
>
> Also, we were told the CE marking applied to these directives. Well, if you
have
> CE marked products in the market prior to July 2006 and you do not have to
apply
> these directives to existing products, then you can not assume a CE marked
> product meets the RoHS directive. Must request the DOC to find out.
>
> Am I all wet here or are these things what the industry knows to be true? The
> more I hear and read on this topic the more frustrating it gets.
>
> Thanks for any replies.
> Brian
>
> Reply Separator
> Subject:RE: RoHS / WEEE Directive Questions
> Author: alexandre.gour...@cmot.xerox.com
> Date:   2/25/2005 9:20 AM
>
> John,
>
> I had the same set of questions for myself (#1 and #2). Does the way they
> specify the limits to be "per homogeneous material" imply that when some
> product (i.e. assembled printed circuit board) is submitted for the
> compliance test and turned into "homogeneous material" by either crushing or
> grinding we are all actually left with a loophole allowing some components
> on the board to be non-RoHS compliant as long as the board as a whole meets
> the spec?
> Can it be extended to the unit where the board is installed to allow the
> banned substance to be even more "diluted"?
> Anyone else in the forum knows the answer, any links?
>
> Best regards,
>
> Alex Gourari
>
> -Original Message-
> From: John Barnes [mailto:jrbar...@iglou.com]
> Sent: Thursday, February 24, 2005 9:14 PM
> To: emc-p...@ieee.org; Jim Eichner
> Subject: Re: RoHS / WEEE Directive Questions
>
>
> Jim Eichner wrote:
>
>>I have a few questions regarding these Directives...
>>
>>1. Does anyone know if the EU has published substance limits yet for
>>the RoHS Directive, or if they have decided to adopt the UK limits
>>(0.01% for Cadmium, 0.1% for the other 5 substances)?
>>
>>2. Are (or will) the limits be "per homogeneous material" as many
>>people expect, or will they be per product (the loophole to end all
>>loopholes)?
>>
>>3. Can anyone point me to the formally published national legislation
>>from each country, transposing the WEEE Directive to law?  How about
>>pointing me to even ONE !?!
>
>
> Jim,
> Your questions #1 and #2 were discussed on the LEADFREE forum last week
> (subscribe at
> http://listserv.ipc.org/scripts/wa.exe?SUBED1=leadfree&A=1   )
>
> Council Decision COM(2004) 606 (
> http://europa.eu.int/eur-lex/en/com/pdf/2004/com2004_0606en01.pdf   )
> amends the Annex of the RoHS Directive to permit not-otherwise-exempted
> homogeneous materials to contain a maximum of:
> * 0.1% lead by weight.
> * 0.1% mercury by weight.
> * 0.01% cadmium by weight.
> * 0.1% hexavalent chromium by weight.
> * 0.1% polybrominated biphenyls by weight.
> * 0.1% polybrominated diphenyl ethers by weight.
>
> There were several postings that said that this decision has passed the
> date where member states could fight it, so it is a done deal.  Several
> other postings said that it hasn't been published in the Official
> Journal of the European Union (OJ) yet, so it still isn't "official".
> Either way, they agreed that these will be the limits for all of the
> countries in the European Union, and not

RE: RE: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

  

-Original Message- 
From: brian_ku...@leco.com [ mailto:brian_ku...@leco.com] 
Sent: Friday, February 25, 2005 7:50 AM 
To: alexandre.gour...@cmot.xerox.com; jrbar...@iglou.com; emc-p...@ieee.org;
jim.eich...@xantrex.com 
Subject: Re:RE: RoHS / WEEE Directive Questions 

John, 

That is not what I'm being told by UL. We just had a mini-seminar from UL on
this topic and we were told that crushing or grinding assemblies together to
"make them homogeneous" is NOT what you do. You have to separate all parts of
all assemblies and break them down as far as you can. The example they gave us
was even surface mounted resistors you have to separate the paint, the metal
end caps, and the base material. They couldn't tell us if we have to remove
the traces from PC boards, but that was the impression they gave us.

Is UL giving us a line or is this the way it will be done? 

They also said that products currently on the market in Europe did not have to
meet these directives unless they were changed is some undefined but fairly
major way. These directives only apply to NEW products being introduced to the
market. Is this true?

Also, we were told the CE marking applied to these directives. Well, if you
have CE marked products in the market prior to July 2006 and you do not have
to apply these directives to existing products, then you can not assume a CE
marked product meets the RoHS directive. Must request the DOC to find out.

Am I all wet here or are these things what the industry knows to be true? The
more I hear and read on this topic the more frustrating it gets.

Thanks for any replies. 
Brian 



I haven't had to face this WEEE question yet, but I wonder if an application
of devious thinking can come up with a workable solution (workable that is
until they get around to outlawing it)?

I wonder if you could take the discarded "assemblies", grind them to powder,
and them compress them into a dense, fused cube. These cubes could be then be
sold as techno objects de art or garden ornaments, possibly at a deep
discount. Instant 100% recycling, with no waste stream! I think I'd like mine
electroless nickel plated.

Ed 

Ed Price 
ed.pr...@cubic.com WB6WSN 
NARTE Certified EMC Engineer & Technician 
Electromagnetic Compatibility Lab 
Cubic Defense Applications 
San Diego, CA USA 
858-505-2780 (Voice) 
858-505-1583 (Fax) 
Military & Avionics EMC Is Our Specialty 

  

 This message
is from the IEEE Product Safety Engineering Society emc-pstc discussion list.
Website: http://www.ieee-pses.org/ 

To post a message to the list, send your e-mail to emc-p...@ieee.org 


Instructions: http://listserv.ieee.org/listserv/request/user-guide.html 


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For help, send mail to the list administrators: 


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For policy questions, send mail to: 


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All emc-pstc postings are archived and searchable on the web at: 


http://www.ieeecommunities.org/emc-pstc

Re:RE: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

John,

That is not what I'm being told by UL. We just had a mini-seminar from UL on
this topic and we were told that crushing or grinding assemblies together to
"make them homogeneous" is NOT what you do. You have to separate all parts of
all assemblies and break them down as far as you can. The example they gave us
was even surface mounted resistors you have to separate the paint, the metal
end
caps, and the base material. They couldn't tell us if we have to remove the
traces from PC boards, but that was the impression they gave us.

Is UL giving us a line or is this the way it will be done?

They also said that products currently on the market in Europe did not have to
meet these directives unless they were changed is some undefined but fairly
major way. These directives only apply to NEW products being introduced to the
market. Is this true?

Also, we were told the CE marking applied to these directives. Well, if you
have
CE marked products in the market prior to July 2006 and you do not have to
apply
these directives to existing products, then you can not assume a CE marked
product meets the RoHS directive. Must request the DOC to find out.

Am I all wet here or are these things what the industry knows to be true? The
more I hear and read on this topic the more frustrating it gets.

Thanks for any replies.
Brian

Reply Separator
Subject:RE: RoHS / WEEE Directive Questions
Author: alexandre.gour...@cmot.xerox.com
List-Post: emc-pstc@listserv.ieee.org
Date:   2/25/2005 9:20 AM

John,

I had the same set of questions for myself (#1 and #2). Does the way they
specify the limits to be "per homogeneous material" imply that when some
product (i.e. assembled printed circuit board) is submitted for the
compliance test and turned into "homogeneous material" by either crushing or
grinding we are all actually left with a loophole allowing some components
on the board to be non-RoHS compliant as long as the board as a whole meets
the spec?
Can it be extended to the unit where the board is installed to allow the
banned substance to be even more "diluted"?
Anyone else in the forum knows the answer, any links?

Best regards,

Alex Gourari


From: John Barnes [mailto:jrbar...@iglou.com]
Sent: Thursday, February 24, 2005 9:14 PM
To: emc-p...@ieee.org; Jim Eichner
Subject: Re: RoHS / WEEE Directive Questions


Jim Eichner wrote:
> I have a few questions regarding these Directives...
>
> 1. Does anyone know if the EU has published substance limits yet for
> the RoHS Directive, or if they have decided to adopt the UK limits
> (0.01% for Cadmium, 0.1% for the other 5 substances)?
>
> 2. Are (or will) the limits be "per homogeneous material" as many
> people expect, or will they be per product (the loophole to end all
> loopholes)?
>
> 3. Can anyone point me to the formally published national legislation
> from each country, transposing the WEEE Directive to law?  How about
> pointing me to even ONE !?!

Jim,
Your questions #1 and #2 were discussed on the LEADFREE forum last week
(subscribe at
http://listserv.ipc.org/scripts/wa.exe?SUBED1=leadfree&A=1   )

Council Decision COM(2004) 606 (
http://europa.eu.int/eur-lex/en/com/pdf/2004/com2004_0606en01.pdf   )
amends the Annex of the RoHS Directive to permit not-otherwise-exempted
homogeneous materials to contain a maximum of:
* 0.1% lead by weight.
* 0.1% mercury by weight.
* 0.01% cadmium by weight.
* 0.1% hexavalent chromium by weight.
* 0.1% polybrominated biphenyls by weight.
* 0.1% polybrominated diphenyl ethers by weight.

There were several postings that said that this decision has passed the
date where member states could fight it, so it is a done deal.  Several
other postings said that it hasn't been published in the Official
Journal of the European Union (OJ) yet, so it still isn't "official".
Either way, they agreed that these will be the limits for all of the
countries in the European Union, and not just for the United Kingdom.

For your question #3, the United Kingdom's draft law for the RoHS
Directive is at
http://www.dti.gov.uk/sustainability/weee/RoHs_Regs_draft.pdf

For information on how the various member states are transposing the
RoHS Directive and the WEEE Directive to national laws, see the January
2005 Perchards Report, "Transposition of the WEEE Directive in Other EU
Member States: January 2005," at
http://www.dti.gov.uk/sustainability/weee/
Perchards_Report_January2005.pdf

I have a massive bibliography (69 pages, references to over 1100 source
documents, over 800 links) on designing electronic products to be
lead-free, RoHS-compliant, and WEEE-compliant at
http://www.dbicorporation.com/rohsbib.htm

My (still under-construction) web page to summarize this data is
http://www.dbicorporation.com/rohs.htm
It is already 50 pages long, with 5 sections fairly complete, and 

Re: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

And further to that, how and where does one register as required in the WEEE
Directive? A central organization (national clearing house) was supposed to
have been created for this purpose, but I can find no evidence that it even
exists. Are there any forms to be filled out?
 
Regards,
 
Ron Pickard
rpick...@hypercom.com
 




To: emc-p...@ieee.org, jim.eich...@xantrex.com
From: jrbar...@iglou.com
Sent by: owner-emc-p...@ieee.org
List-Post: emc-pstc@listserv.ieee.org
Date: 02/24/2005 07:13PM
Subject: Re: RoHS / WEEE Directive Questions

Jim Eichner wrote:
> I have a few questions regarding these Directives...
>
> 1. Does anyone know if the EU has published substance limits yet for
> the RoHS Directive, or if they have decided to adopt the UK limits
> (0.01% for Cadmium, 0.1% for the other 5 substances)?
>
> 2. Are (or will) the limits be "per homogeneous material" as many
> people expect, or will they be per product (the loophole to end all
> loopholes)?
>
> 3. Can anyone point me to the formally published national legislation
> from each country, transposing the WEEE Directive to law?  How about
> pointing me to even ONE !?!

Jim,
Your questions #1 and #2 were discussed on the LEADFREE forum last week
(subscribe at
  http://listserv.ipc.org/scripts/wa.exe?SUBED1=leadfree
<http://listserv.ipc.org/scripts/wa.exe?SUBED1=leadfree&A=1> &A=1  )

Council Decision COM(2004) 606 (
  http://europa.eu.int/eur-lex/en/com/pdf/2004/com2004_0606en01.pdf  )
amends the Annex of the RoHS Directive to permit not-otherwise-exempted
homogeneous materials to contain a maximum of:
* 0.1% lead by weight.
* 0.1% mercury by weight.
* 0.01% cadmium by weight.
* 0.1% hexavalent chromium by weight.
* 0.1% polybrominated biphenyls by weight.
* 0.1% polybrominated diphenyl ethers by weight.

There were several postings that said that this decision has passed the
date where member states could fight it, so it is a done deal.  Several
other postings said that it hasn't been published in the Official
Journal of the European Union (OJ) yet, so it still isn't "official".
Either way, they agreed that these will be the limits for all of the
countries in the European Union, and not just for the United Kingdom.

For your question #3, the United Kingdom's draft law for the RoHS
Directive is at
  http://www.dti.gov.uk/sustainability/weee/RoHs_Regs_draft.pdf

For information on how the various member states are transposing the
RoHS Directive and the WEEE Directive to national laws, see the January
2005 Perchards Report, "Transposition of the WEEE Directive in Other EU
Member States: January 2005," at
  http://www.dti.gov.uk/sustainability/weee/
  Perchards_Report_January2005.pdf

I have a massive bibliography (69 pages, references to over 1100 source
documents, over 800 links) on designing electronic products to be
lead-free, RoHS-compliant, and WEEE-compliant at
  http://www.dbicorporation.com/rohsbib.htm

My (still under-construction) web page to summarize this data is
  http://www.dbicorporation.com/rohs.htm
It is already 50 pages long, with 5 sections fairly complete, and 15
more sections barely blocked out...  I thought that this would be a
1-month project.  I've been working on it almost 2 months now, just
gathering the source documents, which already fill one book shelf and
two file-cabinet drawers.

   John Barnes KS4GL, PE, NCE, ESDC Eng, PSE, SM IEEE
   dBi Corporation
http://www.dbicorporation.com/


This message is from the IEEE Product Safety Engineering Society
emc-pstc discussion list.Website:   http://www.ieee-pses.org/

To post a message to the list, send your e-mail to emc-p...@ieee.org

Instructions:   http://listserv.ieee.org/listserv/request/user-guide.html

List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:

Scott Douglas emcp...@ptcnh.net
Mike Cantwellmcantw...@ieee.org

For policy questions, send mail to:

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Jim Bacher: j.bac...@ieee.org

All emc-pstc postings are archived and searchable on the web at:

http://www.ieeecommunities.org/emc-pstc



 This message
is from the IEEE Product Safety Engineering Society emc-pstc discussion list.
Website: http://www.ieee-pses.org/ 

To post a message to the list, send your e-mail to emc-p...@ieee.org 


Instructions: http://listserv.ieee.org/listserv/request/user-guide.html 


List rules: http://www.ieee-pses.org/listrules.html 


For help, send mail to the list administrators: 


Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org 


For policy questions, send mail to: 


Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org 


All emc-pstc postings are archived and searchable on the web at: 


http://www.ieeecommunities.org/emc-pstc

RE: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

John,

I had the same set of questions for myself (#1 and #2). Does the way they
specify the limits to be "per homogeneous material" imply that when some
product (i.e. assembled printed circuit board) is submitted for the
compliance test and turned into "homogeneous material" by either crushing or
grinding we are all actually left with a loophole allowing some components
on the board to be non-RoHS compliant as long as the board as a whole meets
the spec?
Can it be extended to the unit where the board is installed to allow the
banned substance to be even more "diluted"?
Anyone else in the forum knows the answer, any links?

Best regards,

Alex Gourari


From: John Barnes [mailto:jrbar...@iglou.com]
Sent: Thursday, February 24, 2005 9:14 PM
To: emc-p...@ieee.org; Jim Eichner
Subject: Re: RoHS / WEEE Directive Questions


Jim Eichner wrote:
> I have a few questions regarding these Directives...
>
> 1. Does anyone know if the EU has published substance limits yet for
> the RoHS Directive, or if they have decided to adopt the UK limits
> (0.01% for Cadmium, 0.1% for the other 5 substances)?
>
> 2. Are (or will) the limits be "per homogeneous material" as many
> people expect, or will they be per product (the loophole to end all
> loopholes)?
>
> 3. Can anyone point me to the formally published national legislation
> from each country, transposing the WEEE Directive to law?  How about
> pointing me to even ONE !?!

Jim,
Your questions #1 and #2 were discussed on the LEADFREE forum last week
(subscribe at
   http://listserv.ipc.org/scripts/wa.exe?SUBED1=leadfree&A=1   )

Council Decision COM(2004) 606 (
   http://europa.eu.int/eur-lex/en/com/pdf/2004/com2004_0606en01.pdf   )
amends the Annex of the RoHS Directive to permit not-otherwise-exempted
homogeneous materials to contain a maximum of:
* 0.1% lead by weight.
* 0.1% mercury by weight.
* 0.01% cadmium by weight.
* 0.1% hexavalent chromium by weight.
* 0.1% polybrominated biphenyls by weight.
* 0.1% polybrominated diphenyl ethers by weight.

There were several postings that said that this decision has passed the
date where member states could fight it, so it is a done deal.  Several
other postings said that it hasn't been published in the Official
Journal of the European Union (OJ) yet, so it still isn't "official".
Either way, they agreed that these will be the limits for all of the
countries in the European Union, and not just for the United Kingdom.

For your question #3, the United Kingdom's draft law for the RoHS
Directive is at
   http://www.dti.gov.uk/sustainability/weee/RoHs_Regs_draft.pdf

For information on how the various member states are transposing the
RoHS Directive and the WEEE Directive to national laws, see the January
2005 Perchards Report, "Transposition of the WEEE Directive in Other EU
Member States: January 2005," at
   http://www.dti.gov.uk/sustainability/weee/
   Perchards_Report_January2005.pdf

I have a massive bibliography (69 pages, references to over 1100 source
documents, over 800 links) on designing electronic products to be
lead-free, RoHS-compliant, and WEEE-compliant at
   http://www.dbicorporation.com/rohsbib.htm

My (still under-construction) web page to summarize this data is
   http://www.dbicorporation.com/rohs.htm
It is already 50 pages long, with 5 sections fairly complete, and 15
more sections barely blocked out...  I thought that this would be a
1-month project.  I've been working on it almost 2 months now, just
gathering the source documents, which already fill one book shelf and
two file-cabinet drawers.

John Barnes KS4GL, PE, NCE, ESDC Eng, PSE, SM IEEE
dBi Corporation
http://www.dbicorporation.com/


This message is from the IEEE Product Safety Engineering Society
emc-pstc discussion list.Website:  http://www.ieee-pses.org/

To post a message to the list, send your e-mail to emc-p...@ieee.org

Instructions:  http://listserv.ieee.org/listserv/request/user-guide.html

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For help, send mail to the list administrators:

 Scott Douglas emcp...@ptcnh.net
 Mike Cantwellmcantw...@ieee.org

For policy questions, send mail to:

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 Jim Bacher: j.bac...@ieee.org

All emc-pstc postings are archived and searchable on the web at:

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This message is from the IEEE Product Safety Engineering Society
emc-pstc discussion list.Website:  http://www.ieee-pses.org/

To post a message to the list, send your e-mail to emc-p...@ieee.org

Instructions:  http://listserv.ieee.org/listserv/request/user-guide.html

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For help, send mail to the list administrators:

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RE: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

Jim,

Regarding 3., take a look at:
http://www.dti.gov.uk/sustainability/weee/Perchards_Report_January2005.p
df

Regards,
Kris


From: owner-emc-p...@listserv.ieee.org
[mailto:owner-emc-p...@listserv.ieee.org]On Behalf Of Jim Eichner
Sent: vrijdag 25 februari 2005 1:47
To: EMC-PSTC - Forum
Subject: RE: RoHS / WEEE Directive Questions


I have a few questions regarding these Directives...

1. Does anyone know if the EU has published substance limits yet for the
RoHS Directive, or if they have decided to adopt the UK limits (0.01%
for Cadmium, 0.1% for the other 5 substances)?

2. Are (or will) the limits be "per homogeneous material" as many people
expect, or will they be per product (the loophole to end all loopholes)?

3. Can anyone point me to the formally published national legislation
>from each country, transposing the WEEE Directive to law?  How about
pointing me to even ONE !?!

As always, thanks in advance for your assistance.

Jim Eichner, P.Eng.
Compliance Engineering Manager
Xantrex Technology Inc.
e-mail: jim.eich...@xantrex.com
web: www.xantrex.com

Any opinions expressed are those of my invisible friend.

Confidentiality Notice: This email message, including any attachments,
is for the sole use of the intended recipient(s) and may contain
confidential and privileged information. Any unauthorized review, use,
disclosure or distribution is prohibited. If you are not the intended
recipient, please contact the sender by reply e-mail and destroy all
copies of the original message.




From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org] On Behalf
Of Camille Good
Sent: Monday, December 20, 2004 4:39 PM
To: emc-pstc mailinglist
Cc: Samuel Lifshutz; jeff collins
Subject: RE: RoHS / WEEE Directive Questions

To throw in my 2 cents:

1) Samuel, great synopsis! That also answered some questions I had about
the California law.

2) My understanding of the rule for 0.01% cadmium and 0.1% of everything
else is that rule was published by UK Department of Trades and
Industries (sometimes referred to as DTI), it was their interpretation
of the rules but may or may not be binding on final EU interpretation.
That information is a couple of months old and I think there is supposed
to be some big EU committee meeting that either just recently occurred
or is set to occur early in 2005 where the EU will decide whether or not
to adopt the British DTI limits.  Hopefully there might be someone on
this list who can comment in more depth on this.

3) I haven't heard anything about the EPA adopting nationwide rules
similar to RoHS or WEEE, but in my opinion it would be much more
preferable (from a manufacturer's point of view) to have a single
federal regulation instead of a patchwork of state regulations.

4) ISO 14001 does NOT guarantee compliance with RoHS or WEEE.  It does
have to do with setting up collection points for material that can be
sent to recycling centers, also identification, containment (and
hopefully eventual elimination) of products used in the course of
business that are environmentally hazardous or generate waste that is
environmentally hazardous.
 I know some people who work in a company that is ultimately owned
by a European-based multi-national and the multi-national parent company
insisted the subsidiary get ISO-14001-certified as part of their plan
for compliance with RoHS.  But I think that was more because ISO 14001
forces identification and documentation of procedures and materials that
will affect the environment; so if anyone asks, they can say "Look,
they're ISO 14001 certified and that means they document and follow
their environmental processes!" or something like that.
 I do know that I have never heard anywhere of ISO
14001 certification being required by either RoHS or WEEE and I also
know that the process of ISO 14001 certification does NOT automatically
mean compliance wiht RohS or WEEE.

5) The IPC runs a listserver that deals specifically with lead-free
issues and might expand soon to include RoHS issues in general.  There
has been some discussion there of the California requirements (although
not any detailed comparisons with RoHS & WEEE like you were referring
to).  You might want to post your questions on that list as well.  I
think you can find instructions on how to sign up at www.ipc.org.

-Camille Good
Portland, Oregon

--- Samuel Lifshutz  wrote:

> Jeff:
>
>
>
> My research on the subject,
>
>
>
> The "Green" law applies to Electrical & Electronic products with a
> cord, or a battery (There are few exemptions).
>
>
>
> California Senate Bill 50 signed into law 9/29/04, effective
> immediately:
>
>
>
> 1.   Bans sale of RoHS non-compliant devices as
> of 1 January 2007
>
> 2.   Requires manufacturers to notify all
> retailers, by 1 October 2004,
> which of manufactured products are subject to the waste recycling fee
>

Re: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

Jim Eichner wrote:
> I have a few questions regarding these Directives...
>
> 1. Does anyone know if the EU has published substance limits yet for
> the RoHS Directive, or if they have decided to adopt the UK limits
> (0.01% for Cadmium, 0.1% for the other 5 substances)?
>
> 2. Are (or will) the limits be "per homogeneous material" as many
> people expect, or will they be per product (the loophole to end all
> loopholes)?
>
> 3. Can anyone point me to the formally published national legislation
> from each country, transposing the WEEE Directive to law?  How about
> pointing me to even ONE !?!

Jim,
Your questions #1 and #2 were discussed on the LEADFREE forum last week
(subscribe at
   http://listserv.ipc.org/scripts/wa.exe?SUBED1=leadfree&A=1   )

Council Decision COM(2004) 606 (
   http://europa.eu.int/eur-lex/en/com/pdf/2004/com2004_0606en01.pdf   )
amends the Annex of the RoHS Directive to permit not-otherwise-exempted
homogeneous materials to contain a maximum of:
* 0.1% lead by weight.
* 0.1% mercury by weight.
* 0.01% cadmium by weight.
* 0.1% hexavalent chromium by weight.
* 0.1% polybrominated biphenyls by weight.
* 0.1% polybrominated diphenyl ethers by weight.

There were several postings that said that this decision has passed the
date where member states could fight it, so it is a done deal.  Several
other postings said that it hasn't been published in the Official
Journal of the European Union (OJ) yet, so it still isn't "official".
Either way, they agreed that these will be the limits for all of the
countries in the European Union, and not just for the United Kingdom.

For your question #3, the United Kingdom's draft law for the RoHS
Directive is at
   http://www.dti.gov.uk/sustainability/weee/RoHs_Regs_draft.pdf

For information on how the various member states are transposing the
RoHS Directive and the WEEE Directive to national laws, see the January
2005 Perchards Report, "Transposition of the WEEE Directive in Other EU
Member States: January 2005," at
   http://www.dti.gov.uk/sustainability/weee/
   Perchards_Report_January2005.pdf

I have a massive bibliography (69 pages, references to over 1100 source
documents, over 800 links) on designing electronic products to be
lead-free, RoHS-compliant, and WEEE-compliant at
   http://www.dbicorporation.com/rohsbib.htm

My (still under-construction) web page to summarize this data is
   http://www.dbicorporation.com/rohs.htm
It is already 50 pages long, with 5 sections fairly complete, and 15
more sections barely blocked out...  I thought that this would be a
1-month project.  I've been working on it almost 2 months now, just
gathering the source documents, which already fill one book shelf and
two file-cabinet drawers.

John Barnes KS4GL, PE, NCE, ESDC Eng, PSE, SM IEEE
dBi Corporation
http://www.dbicorporation.com/


This message is from the IEEE Product Safety Engineering Society
emc-pstc discussion list.Website:  http://www.ieee-pses.org/

To post a message to the list, send your e-mail to emc-p...@ieee.org

Instructions:  http://listserv.ieee.org/listserv/request/user-guide.html

List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:

 Scott Douglas emcp...@ptcnh.net
 Mike Cantwellmcantw...@ieee.org

For policy questions, send mail to:

 Richard Nute:   ri...@ieee.org
 Jim Bacher: j.bac...@ieee.org

All emc-pstc postings are archived and searchable on the web at:

http://www.ieeecommunities.org/emc-pstc

RE: RoHS / WEEE Directive Questions

[owner-emc-p...@listserv.ieee.org]

I have a few questions regarding these Directives... 

1. Does anyone know if the EU has published substance limits yet for the
RoHS Directive, or if they have decided to adopt the UK limits (0.01%
for Cadmium, 0.1% for the other 5 substances)?   

2. Are (or will) the limits be "per homogeneous material" as many people
expect, or will they be per product (the loophole to end all loopholes)?

3. Can anyone point me to the formally published national legislation
>from each country, transposing the WEEE Directive to law?  How about
pointing me to even ONE !?!

As always, thanks in advance for your assistance.

Jim Eichner, P.Eng. 
Compliance Engineering Manager
Xantrex Technology Inc. 
e-mail: jim.eich...@xantrex.com 
web: www.xantrex.com 

Any opinions expressed are those of my invisible friend.

Confidentiality Notice: This email message, including any attachments,
is for the sole use of the intended recipient(s) and may contain
confidential and privileged information. Any unauthorized review, use,
disclosure or distribution is prohibited. If you are not the intended
recipient, please contact the sender by reply e-mail and destroy all
copies of the original message.




From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org] On Behalf
Of Camille Good
Sent: Monday, December 20, 2004 4:39 PM
To: emc-pstc mailinglist
Cc: Samuel Lifshutz; jeff collins
Subject: RE: RoHS / WEEE Directive Questions

To throw in my 2 cents:

1) Samuel, great synopsis! That also answered some questions I had about
the California law.

2) My understanding of the rule for 0.01% cadmium and 0.1% of everything
else is that rule was published by UK Department of Trades and
Industries (sometimes referred to as DTI), it was their interpretation
of the rules but may or may not be binding on final EU interpretation.
That information is a couple of months old and I think there is supposed
to be some big EU committee meeting that either just recently occurred
or is set to occur early in 2005 where the EU will decide whether or not
to adopt the British DTI limits.  Hopefully there might be someone on
this list who can comment in more depth on this.

3) I haven't heard anything about the EPA adopting nationwide rules
similar to RoHS or WEEE, but in my opinion it would be much more
preferable (from a manufacturer's point of view) to have a single
federal regulation instead of a patchwork of state regulations.

4) ISO 14001 does NOT guarantee compliance with RoHS or WEEE.  It does
have to do with setting up collection points for material that can be
sent to recycling centers, also identification, containment (and
hopefully eventual elimination) of products used in the course of
business that are environmentally hazardous or generate waste that is
environmentally hazardous.
 I know some people who work in a company that is ultimately owned
by a European-based multi-national and the multi-national parent company
insisted the subsidiary get ISO-14001-certified as part of their plan
for compliance with RoHS.  But I think that was more because ISO 14001
forces identification and documentation of procedures and materials that
will affect the environment; so if anyone asks, they can say "Look,
they're ISO 14001 certified and that means they document and follow
their environmental processes!" or something like that.
 I do know that I have never heard anywhere of ISO
14001 certification being required by either RoHS or WEEE and I also
know that the process of ISO 14001 certification does NOT automatically
mean compliance wiht RohS or WEEE.

5) The IPC runs a listserver that deals specifically with lead-free
issues and might expand soon to include RoHS issues in general.  There
has been some discussion there of the California requirements (although
not any detailed comparisons with RoHS & WEEE like you were referring
to).  You might want to post your questions on that list as well.  I
think you can find instructions on how to sign up at www.ipc.org.

-Camille Good
Portland, Oregon

--- Samuel Lifshutz  wrote:

> Jeff:
>
>
>
> My research on the subject,
>
>
>
> The "Green" law applies to Electrical & Electronic products with a 
> cord, or a battery (There are few exemptions).
>
>
>
> California Senate Bill 50 signed into law 9/29/04, effective 
> immediately:
>
>
>
> 1.   Bans sale of RoHS non-compliant devices as
> of 1 January 2007
>
> 2.   Requires manufacturers to notify all
> retailers, by 1 October 2004,
> which of manufactured products are subject to the waste recycling fee
>
> 3.   Requires retailers to collect recycling
> fees from 1 January 2005
>
> 4.   On or before 1, July 2005, and annually
> thereafter, requires each
> manufacturer of covered devices to submit a report to the Cal 
> Integrated Waste on sales volumes and hazardous substances used.
>
>
&

RE: RoHS / WEEE Directive Questions

[owner-emc-p...@ieee.org]

John:

 

Here is the link to CA SB 50, Chapter 863

 

http://www.boe.ca.gov/sptaxprog/sb_50_bill_20040929_chaptered.htm

 

Samuel Lifshutz

Manager QA

MRV Communications Inc.  

20520 Nordhoff Street

Chatsworth, CA 91311, USA

Tel: (818) 772-6235 x265

Fax: (818) 772-0576

email: slifsh...@mrv.com

www.mrv.com

Registered by QMI to ISO 9001:2000 

 

 

  _  

From: Samuel Lifshutz 
Sent: Tuesday, December 21, 2004 2:15 PM
To: Tyra, John; jeff collins
Cc: emc-p...@ieee.org
Subject: RE: RoHS / WEEE Directive Questions

 

Hi John:

 

Good clarification of a covered electronic device in California Senate Bill 50.

 

The Section 1 of the California Senate Bill No.50, Chapter 863 provides
reference the EU RoHS Directive 2002/95/EC.

 

I attached the SB 50, but the posting to the EMC-PSTC list has been rejected
because it contains an attachment of type 'APPLICATION/OCTET-STREAM'.  

 

Happy Holidays!

 

Samuel Lifshutz

Manager QA

MRV Communications Inc.  

20520 Nordhoff Street

Chatsworth, CA 91311, USA

Tel: (818) 772-6235 x265

Fax: (818) 772-0576

email: slifsh...@mrv.com

www.mrv.com

Registered by QMI to ISO 9001:2000 

 

 

  _  

From: Tyra, John [mailto:john_t...@bose.com] 
Sent: Tuesday, December 21, 2004 10:34 AM
To: Samuel Lifshutz; jeff collins
Cc: emc-p...@ieee.org
Subject: RE: RoHS / WEEE Directive Questions

 

Hello Samuel,

 

Excellent synopsis on the coming regulations!

 

I ran this past our Environmental Group and they had the following
clarification on the California Regs and info on Taiwan which might of
interest to the group:

 

California's SB-50 only applies to the following video display products not to
all electronic equipment

# Cathode ray tube containing devices (CRT devices) with CRTs greater than
four inches measured diagonally (X)

# Cathode ray tubes (CRTs) greater than four inches measured diagonally (X);

# Computer monitors containing cathode ray tubes greater than four inches
measured diagonally (X) 

# Laptop computers with liquid crystal display (LCD) screens greater than four
inches measured diagonally (X)

# LCD containing desktop monitors greater than four inches measured diagonally
(X) 

# Televisions containing cathode ray tubes greater than four inches measured
diagonally (X)

Televisions containing liquid crystal display (LCD) screens greater than four
inches measured diagonally (X) (added December 2004)

Plasma televisions with screens greater than four inches measured diagonally
(X) (added December 2004)

There is no comparison between prop 65 and any of these directives.  Prop 65
does not actually ban anything.  It requires notification if consumers may be
exposed to harmful levels.

 

Taiwan has also recently passed rules which may require compliance to RoHS for
sales to Taiwan.

 

Have a happy and safe Holiday everyone

 

Best regards,

 

John Tyra

Product Safety and Regulatory

Compliance Manager 

Bose Corporation

The Mountain, MS-450

Framingham, MA 01701-9168

phone: 508-766-1502

fax: 508-766-1145


From: owner-emc-p...@listserv.ieee.org 
mailto:owner-emc-p...@listserv.ieee.org] On Behalf Of Samuel Lifshutz
Sent: Monday, December 20, 2004 6:24 PM
To: jeff collins
Cc: emc-p...@ieee.org
Subject: RE: RoHS / WEEE Directive Questions

Jeff:

 

My research on the subject,

 

The “Green” law applies to Electrical & Electronic products with a cord,
or a battery (There are few exemptions). 

 

California Senate Bill 50 signed into law 9/29/04, effective immediately:

 

1.   Bans sale of RoHS non-compliant devices as of 1 January 2007

2.   Requires manufacturers to notify all retailers, by 1 October 2004,
which of manufactured products are subject to the waste recycling fee

3.   Requires retailers to collect recycling fees from 1 January 2005

4.   On or before 1, July 2005, and annually thereafter, requires each
manufacturer of covered devices to submit a report to the Cal Integrated Waste
on sales volumes and hazardous substances used.

 

Japanese legislation introduced voluntary compliance law in 2002.

 

China regulations follow RoHS & WEEE Directives from 1 July 2006.

 

Other, like EPA, Maine, Washington, Oregon, Maryland, Minnesota, New Jersey,
Alberta, Ontario and Australia, established or considering recycling programs.

 

Products put on the market after 1 July 2006 (RoHS Directive) shall not exceed
the limits of maximum allowed concentration for the following substances:

1.   Lead - Pb  .1%

2.   Mercury - Hg .1%

3.   Cadmium - (Cd) .01%

4.   Hexavalent Chromium - Cr(Vi) .1%

5.   Polybrominated biphenyls – PBB.1%

6.   Polybrominated diphenyl ethers – PBDE  .1%

 

* Producer will be required to issue a Supplier’s Declaration on
RoHS conformity

* Producer will have to obtai

RE: RoHS / WEEE Directive Questions

[owner-emc-p...@ieee.org]

Hi John:

 

Good clarification of a covered electronic device in California Senate Bill 50.

 

The Section 1 of the California Senate Bill No.50, Chapter 863 provides
reference the EU RoHS Directive 2002/95/EC.

 

I attached the SB 50, but the posting to the EMC-PSTC list has been rejected
because it contains an attachment of type 'APPLICATION/OCTET-STREAM'.  

 

Happy Holidays!

 

Samuel Lifshutz

Manager QA

MRV Communications Inc.  

20520 Nordhoff Street

Chatsworth, CA 91311, USA

Tel: (818) 772-6235 x265

Fax: (818) 772-0576

email: slifsh...@mrv.com

www.mrv.com

Registered by QMI to ISO 9001:2000 

 

 

  _  

From: Tyra, John [mailto:john_t...@bose.com] 
Sent: Tuesday, December 21, 2004 10:34 AM
To: Samuel Lifshutz; jeff collins
Cc: emc-p...@ieee.org
Subject: RE: RoHS / WEEE Directive Questions

 

Hello Samuel,

 

Excellent synopsis on the coming regulations!

 

I ran this past our Environmental Group and they had the following
clarification on the California Regs and info on Taiwan which might of
interest to the group:

 

California's SB-50 only applies to the following video display products not to
all electronic equipment

# Cathode ray tube containing devices (CRT devices) with CRTs greater than
four inches measured diagonally (X)

# Cathode ray tubes (CRTs) greater than four inches measured diagonally (X);

# Computer monitors containing cathode ray tubes greater than four inches
measured diagonally (X) 

# Laptop computers with liquid crystal display (LCD) screens greater than four
inches measured diagonally (X)

# LCD containing desktop monitors greater than four inches measured diagonally
(X) 

# Televisions containing cathode ray tubes greater than four inches measured
diagonally (X)

Televisions containing liquid crystal display (LCD) screens greater than four
inches measured diagonally (X) (added December 2004)

Plasma televisions with screens greater than four inches measured diagonally
(X) (added December 2004)

There is no comparison between prop 65 and any of these directives.  Prop 65
does not actually ban anything.  It requires notification if consumers may be
exposed to harmful levels.

 

Taiwan has also recently passed rules which may require compliance to RoHS for
sales to Taiwan.

 

Have a happy and safe Holiday everyone

 

Best regards,

 

John Tyra

Product Safety and Regulatory

Compliance Manager 

Bose Corporation

The Mountain, MS-450

Framingham, MA 01701-9168

phone: 508-766-1502

fax: 508-766-1145


From: owner-emc-p...@listserv.ieee.org 
mailto:owner-emc-p...@listserv.ieee.org] On Behalf Of Samuel Lifshutz
Sent: Monday, December 20, 2004 6:24 PM
To: jeff collins
Cc: emc-p...@ieee.org
Subject: RE: RoHS / WEEE Directive Questions

Jeff:

 

My research on the subject,

 

The “Green” law applies to Electrical & Electronic products with a cord,
or a battery (There are few exemptions). 

 

California Senate Bill 50 signed into law 9/29/04, effective immediately:

 

1.   Bans sale of RoHS non-compliant devices as of 1 January 2007

2.   Requires manufacturers to notify all retailers, by 1 October 2004,
which of manufactured products are subject to the waste recycling fee

3.   Requires retailers to collect recycling fees from 1 January 2005

4.   On or before 1, July 2005, and annually thereafter, requires each
manufacturer of covered devices to submit a report to the Cal Integrated Waste
on sales volumes and hazardous substances used.

 

Japanese legislation introduced voluntary compliance law in 2002.

 

China regulations follow RoHS & WEEE Directives from 1 July 2006.

 

Other, like EPA, Maine, Washington, Oregon, Maryland, Minnesota, New Jersey,
Alberta, Ontario and Australia, established or considering recycling programs.

 

Products put on the market after 1 July 2006 (RoHS Directive) shall not exceed
the limits of maximum allowed concentration for the following substances:

1.   Lead - Pb  .1%

2.   Mercury - Hg .1%

3.   Cadmium - (Cd) .01%

4.   Hexavalent Chromium - Cr(Vi) .1%

5.   Polybrominated biphenyls – PBB.1%

6.   Polybrominated diphenyl ethers – PBDE  .1%

 

* Producer will be required to issue a Supplier’s Declaration on
RoHS conformity

* Producer will have to obtain assurance (Supplier’s Declaration)
>from their suppliers that materials/components comply with ROHS concentration
levels

* Producer may wish to undertake own analysis (budget $ for analysis
services) for verification, or where no Supplier Declaration exists

* The enforcement authority will carry out market surveillance and may
conduct tests by unscrewing, cutting, crushing, grinding and abrasive
processes to measure maximum concentration by weight in homogeneous materials.

 

On offences and penalties:

1.  

RE: RoHS / WEEE Directive Questions

[owner-emc-p...@ieee.org]

Hello Samuel,
 
Excellent synopsis on the coming regulations!
 
I ran this past our Environmental Group and they had the following
clarification on the California Regs and info on Taiwan which might of
interest to the group:
 
California's SB-50 only applies to the following video display products not to
all electronic equipment

# Cathode ray tube containing devices (CRT devices) with CRTs greater than
four inches measured diagonally (X)
# Cathode ray tubes (CRTs) greater than four inches measured diagonally (X);
# Computer monitors containing cathode ray tubes greater than four inches
measured diagonally (X) 
# Laptop computers with liquid crystal display (LCD) screens greater than four
inches measured diagonally (X)
# LCD containing desktop monitors greater than four inches measured diagonally
(X) 
# Televisions containing cathode ray tubes greater than four inches measured
diagonally (X)
Televisions containing liquid crystal display (LCD) screens greater than four
inches measured diagonally (X) (added December 2004)
Plasma televisions with screens greater than four inches measured diagonally
(X) (added December 2004)

There is no comparison between prop 65 and any of these directives.  Prop 65
does not actually ban anything.  It requires notification if consumers may be
exposed to harmful levels.
 
Taiwan has also recently passed rules which may require compliance to RoHS for
sales to Taiwan.
 
Have a happy and safe Holiday everyone
 
Best regards,
 
John Tyra

Product Safety and Regulatory

Compliance Manager 

Bose Corporation

The Mountain, MS-450

Framingham, MA 01701-9168

phone: 508-766-1502

fax: 508-766-1145


From: owner-emc-p...@listserv.ieee.org 
mailto:owner-emc-p...@listserv.ieee.org] On Behalf Of Samuel Lifshutz
Sent: Monday, December 20, 2004 6:24 PM
To: jeff collins
Cc: emc-p...@ieee.org
Subject: RE: RoHS / WEEE Directive Questions



Jeff:

 

My research on the subject,

 

The “Green” law applies to Electrical & Electronic products with a cord,
or a battery (There are few exemptions). 

 

California Senate Bill 50 signed into law 9/29/04, effective immediately:

 

1.   Bans sale of RoHS non-compliant devices as of 1 January 2007

2.   Requires manufacturers to notify all retailers, by 1 October 2004,
which of manufactured products are subject to the waste recycling fee

3.   Requires retailers to collect recycling fees from 1 January 2005

4.   On or before 1, July 2005, and annually thereafter, requires each
manufacturer of covered devices to submit a report to the Cal Integrated Waste
on sales volumes and hazardous substances used.

 

Japanese legislation introduced voluntary compliance law in 2002.

 

China regulations follow RoHS & WEEE Directives from 1 July 2006.

 

Other, like EPA, Maine, Washington, Oregon, Maryland, Minnesota, New Jersey,
Alberta, Ontario and Australia, established or considering recycling programs.

 

Products put on the market after 1 July 2006 (RoHS Directive) shall not exceed
the limits of maximum allowed concentration for the following substances:

1.   Lead - Pb  .1%

2.   Mercury - Hg .1%

3.   Cadmium - (Cd) .01%

4.   Hexavalent Chromium - Cr(Vi) .1%

5.   Polybrominated biphenyls – PBB.1%

6.   Polybrominated diphenyl ethers – PBDE  .1%

 

* Producer will be required to issue a Supplier’s Declaration on
RoHS conformity

* Producer will have to obtain assurance (Supplier’s Declaration)
>from their suppliers that materials/components comply with ROHS concentration
levels

* Producer may wish to undertake own analysis (budget $ for analysis
services) for verification, or where no Supplier Declaration exists

* The enforcement authority will carry out market surveillance and may
conduct tests by unscrewing, cutting, crushing, grinding and abrasive
processes to measure maximum concentration by weight in homogeneous materials.

 

On offences and penalties:

1.   For failing to submit compliance documentation liable to a fine up to
level 5 on standard scale

2.   For failing to comply with RoHS could result in unlimited fine on
conviction on indictment

3.   Allows for a third party prosecution

 

On WEEE Directive:

 

* Products sold in after 13 August 2005 (WEEE Directive) shall have a
label (a symbol) that it is a subject to collection for recycling (Will be
checked by Customs)

* Producers options for collection are: 

1.   Take back arrangements

2.   Membership of distributor compliance scheme with state-approved
recyclers and assumption of the cost.

 

Registration to ISO 14000 is not de-facto compliance to ROHS & WEEE.

 

Regards,

 

Samuel Lifshutz

 

 


  _  


From: jeff collins [mailto:jeffcollin...@yahoo.com] 
Sent: Monday, December 20, 20

RE: RoHS / WEEE Directive Questions

[owner-emc-p...@ieee.org]

ority will carry out
> market surveillance and
> may conduct tests by unscrewing, cutting, crushing,
> grinding and abrasive
> processes to measure maximum concentration by weight
> in homogeneous
> materials.
>
>
>
> On offences and penalties:
>
> 1.   For failing to submit compliance
> documentation liable to a fine up
> to level 5 on standard scale
>
> 2.   For failing to comply with RoHS could
> result in unlimited fine on
> conviction on indictment
>
> 3.   Allows for a third party prosecution
>
>
>
> On WEEE Directive:
>
>
>
> * Products sold in after 13 August 2005
> (WEEE Directive) shall have
> a label (a symbol) that it is a subject to
> collection for recycling (Will be
> checked by Customs)
>
> * Producers options for collection are:
>
> 1.   Take back arrangements
>
> 2.   Membership of distributor compliance scheme
> with state-approved
> recyclers and assumption of the cost.
>
>
>
> Registration to ISO 14000 is not de-facto compliance
> to ROHS & WEEE.
>
>
>
> Regards,
>
>
>
> Samuel Lifshutz
>
>
>
>
>
>_
>
> From: jeff collins [mailto:jeffcollin...@yahoo.com]
> Sent: Monday, December 20, 2004 1:15 PM
> To: emc-p...@ieee.org
> Subject: RoHS / WEEE Directive Questions
>
>
>
> Group,
>
>
>
> I'm working on a project assessing compliance to
> these two directives which
> are mandatory in the EU.  I have come up with the
> following questions that
> may be of concern to others involved with these
> directives.
>
>
>
> * Many of the RoHS/WEEE restricted substances are
> also restricted in the
> State of California under Proposition 65. Is anyone
> addressing CA. Prop 65
> compliance and is there any daylight between it and
> RoHS/WEEE?
>
>
>
> * Is the EPA in the US implementing or in the
> process of implementing
> similar restrictions? If so when and will it
> parallel RoHS and WEEE.
>
>
>
> * How do these directives tie into a manufacturer
> that has achieved ISO
> 14000 compliance, evidenced by a independent 3rd
> party agency? Can the ISO
> 14000 certification be considered as compliance by
> defacto to the RoHS/WEEE
> Directives? Has anyone looked at comparing ISO 14K
> to
=== message truncated ===


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RE: RoHS / WEEE Directive Questions

[owner-emc-p...@ieee.org]

Jeff:

 

My research on the subject,

 

The “Green” law applies to Electrical & Electronic products with a cord,
or a battery (There are few exemptions). 

 

California Senate Bill 50 signed into law 9/29/04, effective immediately:

 

1.   Bans sale of RoHS non-compliant devices as of 1 January 2007

2.   Requires manufacturers to notify all retailers, by 1 October 2004,
which of manufactured products are subject to the waste recycling fee

3.   Requires retailers to collect recycling fees from 1 January 2005

4.   On or before 1, July 2005, and annually thereafter, requires each
manufacturer of covered devices to submit a report to the Cal Integrated Waste
on sales volumes and hazardous substances used.

 

Japanese legislation introduced voluntary compliance law in 2002.

 

China regulations follow RoHS & WEEE Directives from 1 July 2006.

 

Other, like EPA, Maine, Washington, Oregon, Maryland, Minnesota, New Jersey,
Alberta, Ontario and Australia, established or considering recycling programs.

 

Products put on the market after 1 July 2006 (RoHS Directive) shall not exceed
the limits of maximum allowed concentration for the following substances:

1.   Lead - Pb  .1%

2.   Mercury - Hg .1%

3.   Cadmium - (Cd) .01%

4.   Hexavalent Chromium - Cr(Vi) .1%

5.   Polybrominated biphenyls – PBB.1%

6.   Polybrominated diphenyl ethers – PBDE  .1%

 

* Producer will be required to issue a Supplier’s Declaration on
RoHS conformity

* Producer will have to obtain assurance (Supplier’s Declaration)
>from their suppliers that materials/components comply with ROHS concentration
levels

* Producer may wish to undertake own analysis (budget $ for analysis
services) for verification, or where no Supplier Declaration exists

* The enforcement authority will carry out market surveillance and may
conduct tests by unscrewing, cutting, crushing, grinding and abrasive
processes to measure maximum concentration by weight in homogeneous materials.

 

On offences and penalties:

1.   For failing to submit compliance documentation liable to a fine up to
level 5 on standard scale

2.   For failing to comply with RoHS could result in unlimited fine on
conviction on indictment

3.   Allows for a third party prosecution

 

On WEEE Directive:

 

* Products sold in after 13 August 2005 (WEEE Directive) shall have a
label (a symbol) that it is a subject to collection for recycling (Will be
checked by Customs)

* Producers options for collection are: 

1.   Take back arrangements

2.   Membership of distributor compliance scheme with state-approved
recyclers and assumption of the cost.

 

Registration to ISO 14000 is not de-facto compliance to ROHS & WEEE.

 

Regards,

 

Samuel Lifshutz

 

 

  _  

From: jeff collins [mailto:jeffcollin...@yahoo.com] 
Sent: Monday, December 20, 2004 1:15 PM
To: emc-p...@ieee.org
Subject: RoHS / WEEE Directive Questions

 

Group,

 

I'm working on a project assessing compliance to these two directives which
are mandatory in the EU.  I have come up with the following questions that may
be of concern to others involved with these directives.

 

* Many of the RoHS/WEEE restricted substances are also restricted in the State
of California under Proposition 65. Is anyone addressing CA. Prop 65
compliance and is there any daylight between it and RoHS/WEEE?

 

* Is the EPA in the US implementing or in the process of implementing similar
restrictions? If so when and will it parallel RoHS and WEEE.

 

* How do these directives tie into a manufacturer that has achieved ISO 14000
compliance, evidenced by a independent 3rd party agency? Can the ISO 14000
certification be considered as compliance by defacto to the RoHS/WEEE
Directives? Has anyone looked at comparing ISO 14K to the RoHS and WEEE
Directive. ( IS0 14K is a guideline regarding the impact to the environment
through an environmental management scheme)

 

 

Thanks in advance,

 

Jeff Collins

 This message
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 This message
is from the

Re: RoHS / WEEE Directive Questions

[owner-emc-p...@ieee.org]

Jeff,

Though I am not very familiar with Prop 65.  I can inform you that the
Peoples Republic of the great state of Ca. have enacted new legislation
that greatly coincides with WEEE/RoHS.  In fact if you get a chance to
read it, it comments on the EU directives.  If I remember correctly it
is set to take effect on 1/1/06.

Though there is no federal plans, that I know of, you will find that
individual counties around the US are creating similar laws on these
materials if you put time in to researching this.

I don't have any information on ISO 14000 so I can answer that part of
your question.  I hope this helps.

Happy Holidays!
Josh

jeff collins wrote:
> Group,
>
> I'm working on a project assessing compliance to these two directives
> which are mandatory in the EU.  I have come up with the following
> questions that may be of concern to others involved with these directives.
>
> * Many of the RoHS/WEEE restricted substances are also restricted in the
> State of California under Proposition 65. Is anyone addressing CA. Prop
> 65 compliance and is there any daylight between it and RoHS/WEEE?
>
> * Is the EPA in the US implementing or in the process of implementing
> similar restrictions? If so when and will it parallel RoHS and WEEE.
>
> * How do these directives tie into a manufacturer that has achieved ISO
> 14000 compliance, evidenced by a independent 3rd party agency? Can the
> ISO 14000 certification be considered as compliance by defacto to the
> RoHS/WEEE Directives? Has anyone looked at comparing ISO 14K to the RoHS
> and WEEE Directive. ( IS0 14K is a guideline regarding the impact to the
> environment through an environmental management scheme)
>
>
> Thanks in advance,
>
> Jeff Collins
>  This
> message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. Website: http://www.ieee-pses.org/
>
> To post a message to the list, send your e-mail to emc-p...@ieee.org
>
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>
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>
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>
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>
> All emc-pstc postings are archived and searchable on the web at:
>
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>

--
Josh Wiseman
CE Lab Manager, L F Research


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RoHS / WEEE Directive Questions

[owner-emc-p...@ieee.org]

Group,
 
I'm working on a project assessing compliance to these two directives which
are mandatory in the EU.  I have come up with the following questions that may
be of concern to others involved with these directives.
 
* Many of the RoHS/WEEE restricted substances are also restricted in the State
of California under Proposition 65. Is anyone addressing CA. Prop 65
compliance and is there any daylight between it and RoHS/WEEE?
 
* Is the EPA in the US implementing or in the process of implementing similar
restrictions? If so when and will it parallel RoHS and WEEE.
 
* How do these directives tie into a manufacturer that has achieved ISO 14000
compliance, evidenced by a independent 3rd party agency? Can the ISO 14000
certification be considered as compliance by defacto to the RoHS/WEEE
Directives? Has anyone looked at comparing ISO 14K to the RoHS and WEEE
Directive. ( IS0 14K is a guideline regarding the impact to the environment
through an environmental management scheme)
 
 
Thanks in advance,
 
Jeff Collins
 This message
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Re: WEEE Directive

[owner-emc-p...@listserv.ieee.org]

http://www.ieee-pses.org/symposium
  http://www.emc2004.org/


Ian,

The WEEE Directive is (as with all EU directives) an instruction to Member 
States to pass national laws that implement the essential provisions of the 
directive.  This is a long-winded way of saying that the measures relating to 
recycling will differ between, say, the UK and Germany.  Therefore, the chances 
are that there will be no single answer to your question that applies across 
all Member States.

National legislation implimenting the WEEE Directive does not yet exist in all 
Member States.  For instance, in the UK the consultation process for 
implementing the WEEE and RoHS directives has only recently started: see the 
DTI web site at

http://www.dti.gov.uk/sustainability/weee/

According to the DTI's consultation proposals, the UK will be "applying a light 
touch approach to implementing" the eco-design requirements of the WEEED.  
Other countries may be producing (or may already have produced) national 
legislation that does not adopt such a 'light touch' to eco-design.

{In case you don't keep up with the standards scene, IEC have just set up a new 
Technical Committee scoped to look at environmental issues.  Our lives are set 
to become even more ‘interesting’}.

So, to answer your question "is this actually happening on the ground" the 
answer is no, except in the case of those companies who recycle products 
voluntarily.  Perhaps we’ll hear from a few such companies to see how they are 
getting on and what approaches they’re taking?

While protection of the environment is important to Europeans (more so than it 
is to George W it seems) it is also recognised that measures need to be 
affordable.  It seems to me that scrap from products collected under the 
WEEED’s provision will have an economic value.  To turn this scrap back into 
raw material useful for making new product will require recycling.  If the 
scrap is relatively pure it will require less recycling and so will command a 
higher price.  Throwing a mixture of products into a great big grinding machine 
is therefore not yield the highest value scrap.  Equally, employing hordes of 
people to manually separate every part of an equipment into its components is 
likely to cost so much that nobody will purchase the resulting scrap.

Regards,

Richard Hughes



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WEEE Directive

[owner-emc-p...@listserv.ieee.org]

http://www.ieee-pses.org/symposium http://www.emc2004.org/
-- 
Forum members
 
The WEEE Directive talks about products covered by WEEE being dismantled for
recycling and the Department of Trade and Industry literature, goes into some
detail about this. However is this actually happening on the ground, is there
going to be men in white coats and electric screwdrivers / socket sets
dismantling everything covered by WEEE by hand. 
 
One Compliance Engineer recently told me units would be broken down by
mechanical means, could members please confirm this.
 
Thanks for your help in advanve
 
Ian White
 

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RE: WEEE Directive - Electrolytic caps

[owner-emc-p...@majordomo.ieee.org]

Sylvia,

The WEEE directive states (Annex II, Point 1, last bullet):

"electrolyte capacitors containing substances of concern (height > 25mm,
Diameter > 25mm or proportionately similar volume)"

A rod 25mm high and 25 mm in diameter has a volume of 12.3 um^3. Since
converting to cubic mm is always an exercise that takes me 10 minutes to get
right, I'll leave that part up to you.   8-)

Here's a working link to the WEEE directive:
http://europa.eu.int/smartapi/cgi/sga_d
c?smartapi!celexapi!prod!CELEXnumdoc&lg=EN&numdoc=32002L0096&model=guichett

Cheers,
Marko

Volume of a rod = height x Pi x Radius^2


From: owner-emc-p...@majordomo.ieee.org
[mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of ext Sylvia Toma
Sent: Monday, May 03, 2004 3:58 PM
To: emc-p...@majordomo.ieee.org
Subject: RE: WEEE Directive



Hello,

I saved an old email below regarding electrolytic
capacitors.  Could someone elaborate on what is the
specified volume of substances to be of concern within
the electrolytic capacitors?  I tried using the link
provided below and couldn't found what I need.  

Looking forward to your prompt response.

Best Regards,
Sylvia 


From: richwo...@tycoint.com
[mailto:richwo...@tycoint.com]
Sent: Tuesday, January 21, 2003 5:09 AM
To: emc-p...@majordomo.ieee.org
Subject: RE: WEEE Directive



After some additional research, I found my answer.
Electrolyte capacitors
contain substances of concern if the volume of the
device exceeds a
specified minumum. In that case, the metals are to be
recovered and the rest
is to be treated by high temperatures. Additional
information on the WEEE
recovery process can be found in
http://www1.oecd.org/ehs/Waste/AUTLoSt.doc

Richard Woods
Sensormatic Electronics
Tyco International


>  -Original Message-
> From: WOODS, RICHARD  
> Sent: Monday, January 20, 2003 9:38 AM
> To:   'emc-pstc'
> Subject:  WEEE Directive
> 
> Annex II of the draft WEEE Directive lists materials
and components that
> must be removed for selective treatment including
"Electrolyte capacitors
> containing substances of concern . . ."
> 
> Other than the four heavy metals and PCBs, what
"substances of concern",
> if any, may be found in electrolytic capacitors?
> 
> Richard Woods
> Sensormatic Electronics
> Tyco International
> 
> 
> 


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Technical Committee emc-pstc discussion list.

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RE: WEEE Directive

[owner-emc-p...@majordomo.ieee.org]

Hello,

I saved an old email below regarding electrolytic
capacitors.  Could someone elaborate on what is the
specified volume of substances to be of concern within
the electrolytic capacitors?  I tried using the link
provided below and couldn't found what I need.  

Looking forward to your prompt response.

Best Regards,
Sylvia 


From: richwo...@tycoint.com
[mailto:richwo...@tycoint.com]
Sent: Tuesday, January 21, 2003 5:09 AM
To: emc-p...@majordomo.ieee.org
Subject: RE: WEEE Directive



After some additional research, I found my answer.
Electrolyte capacitors
contain substances of concern if the volume of the
device exceeds a
specified minumum. In that case, the metals are to be
recovered and the rest
is to be treated by high temperatures. Additional
information on the WEEE
recovery process can be found in
http://www1.oecd.org/ehs/Waste/AUTLoSt.doc

Richard Woods
Sensormatic Electronics
Tyco International


>  -Original Message-
> From: WOODS, RICHARD  
> Sent: Monday, January 20, 2003 9:38 AM
> To:   'emc-pstc'
> Subject:  WEEE Directive
> 
> Annex II of the draft WEEE Directive lists materials
and components that
> must be removed for selective treatment including
"Electrolyte capacitors
> containing substances of concern . . ."
> 
> Other than the four heavy metals and PCBs, what
"substances of concern",
> if any, may be found in electrolytic capacitors?
> 
> Richard Woods
> Sensormatic Electronics
> Tyco International
> 
> 
> 


This message is from the IEEE EMC Society Product
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Technical Committee emc-pstc discussion list.

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RE: Crossed out wheelie bin symbol (WEEE Directive)

[Crabb, John]

In directive 93/86/EEC (relating to batteries containing certain dangerous
substances),
it says "the symbol shall cover 3% of the area of the largest side of the
battery
or accumulator, up to a maximum size of 5 cm x 5 cm.  For cylinrical cells
the symbol
shall 3% of half the surface area of the battery or accumulator and shall a
maximum
size of 5 cm x 5 cm."

Not a lot of help, I'm afraid.
I thought "wheelie bin" was unique to Scotland.
Regards,
John Crabb,  (Product Safety) , 
NCR  Financial Solutions Group Ltd.,  Discovery Centre, 
3 Fulton Road, Dundee, Scotland, DD2 4SW
E-Mail :john.cr...@scotland.ncr.com
Tel: +44 (0)1382-592289  (direct ). Fax +44 (0)1382-622243.   



From: James, Chris [mailto:c...@dolby.co.uk] 
Sent: 27 March 2003 14:27
To: emc-p...@majordomo.ieee.org
Subject: Crossed out wheelie bin symbol (WEEE Directive)




Anyone know if there is a size requirement for this symbol? 

i.e. not less than a certain height as applies to the CE mark which must be
at least 5mm tall.

Regards, 

Chris 
___ 
Chris James 
Engineering Services Manager 
Dolby Laboratories, Inc. (UK) 


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RE: Crossed out wheelie bin symbol (WEEE Directive)

[richwo...@tycoint.com]

The directive says "The symbol must be printed visibly, legibly and
indelibly." No minimum size is specified.

Richard Woods
Sensormatic Electronics
Tyco International



From: James, Chris [mailto:c...@dolby.co.uk]
Sent: Thursday, March 27, 2003 9:27 AM
To: emc-p...@majordomo.ieee.org
Subject: Crossed out wheelie bin symbol (WEEE Directive)




Anyone know if there is a size requirement for this symbol? 

i.e. not less than a certain height as applies to the CE mark which must
be at least 5mm tall.

Regards, 

Chris 
___ 
Chris James 
Engineering Services Manager 
Dolby Laboratories, Inc. (UK) 


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Crossed out wheelie bin symbol (WEEE Directive)

[James, Chris]

Anyone know if there is a size requirement for this symbol? 

i.e. not less than a certain height as applies to the CE mark which must
be at least 5mm tall.

Regards, 

Chris 
___ 
Chris James 
Engineering Services Manager 
Dolby Laboratories, Inc. (UK) 


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RE: WEEE Directive

[richwo...@tycoint.com]

After some additional research, I found my answer. Electrolyte capacitors
contain substances of concern if the volume of the device exceeds a
specified minumum. In that case, the metals are to be recovered and the rest
is to be treated by high temperatures. Additional information on the WEEE
recovery process can be found in
http://www1.oecd.org/ehs/Waste/AUTLoSt.doc

Richard Woods
Sensormatic Electronics
Tyco International


>  -Original Message-
> From: WOODS, RICHARD  
> Sent: Monday, January 20, 2003 9:38 AM
> To:   'emc-pstc'
> Subject:  WEEE Directive
> 
> Annex II of the draft WEEE Directive lists materials and components that
> must be removed for selective treatment including "Electrolyte capacitors
> containing substances of concern . . ."
> 
> Other than the four heavy metals and PCBs, what "substances of concern",
> if any, may be found in electrolytic capacitors?
> 
> Richard Woods
> Sensormatic Electronics
> Tyco International
> 
> 
> 


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WEEE Directive

[Neil Helsby]

Apologies to all for false information on my recent submission.

The DTI have done the dirty on me! The current draft WEEE document looks 
identical 
to the version that I downloaded some time ago. It has the same numbers 
and dates etc. on the front page and I assumed (foolishly) that it was 
unchanged.

However, investigation showed that although the text of the main body 
appears to be unchanged, it has been modified to print out on more pages 
– what an example of minimising resources! It has also added the extra 
Annexes.

My interpretation of the reference to ALL items in section 1 of Annex II 
is to question the term "separately collected WEEE". Sections 15 & 16 of 
the "Whereas" at the commencement of the draft indicate this to be items 
collected separate from general household waste. Considering the 
reference to Article 4 of directive 75/442/EEC. This details measures "to
ensure that waste is recovered or disposed of without endangering human 
health and without using processes or methods which could harm the 
environment, and in particular:
without risk to water, air, soil and plants and animals,
without causing a nuisance through noise or odours,
without adversely affecting the countryside or places of special 
interest.
Member States shall also take the necessary measures to prohibit the 
abandonment, dumping or uncontrolled disposal of waste."

So the question seems to be "how are you going to dispose of the product 
at its end of life?" If dangerous substances are involved in some 
components (as per RHoS), then they must be dealt with accordingly. 

Anyone with further thoughts?

Regards,

Neil Helsby


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Re: WEEE Directive

[Neil Helsby]

I think that you are looking at an old draft of the directive (2000). Go 
to dti.gov.uk/support/summary.htm for a draft issued 8 Nov 02 and page 
down to "update on chnages to the WEEE". It does not have any annex, nor 
can I find a reference to capacitors.

Regards,

Neil Helsby


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WEEE Directive

[richwo...@tycoint.com]

Annex II of the draft WEEE Directive lists materials and components that
must be removed for selective treatment including "Electrolyte capacitors
containing substances of concern . . ."

Other than the four heavy metals and PCBs, what "substances of concern", if
any, may be found in electrolytic capacitors?

Richard Woods
Sensormatic Electronics
Tyco International





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WEEE directive and halogen (PVC) wire insulation

[David Heald]

Folks,
  I've been searching all afternoon for recent news on halogen flame
retardent regulation in the EU.  I'm beginning to think that other than
brominated flame retardents, there really is not much current concern and
the risks involved with accelerated fire spread (over that with halogenated
flame retardents) outweigh the environmental concerns from chemical release
during burning or recycling.  (I'm trying to make a decision on wire
insulation specificaitons)

Does anyone know where the WEEE and/or EEE is headed in this regard?  The
last official info I could find was April 2000.

Thanks,
Dave Heald

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Looking for WEEE Directive Expert

[Don_MacArthur]

Hello Group,

I am looking for a consultant who understands the upcoming WEEE Directive.  Any
recommendations?  Email me at don_macart...@selinc.com

Thanks,
Don
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Re: WEEE Directive

[Alan E Hutley]

Hi John

WEEE comes into effect 1st January 2007
Alan E Hutley
EMC Compliance Journal
- Original Message -
From: "John Juhasz" 
To: 
Sent: Thursday, December 06, 2001 9:38 PM
Subject: WEEE Directive


>
>
> I am trying to find a link to the draft of the actual WEEE (Waste
Electrical
> and Electronic Equipment) Directive.
> What I found thus far at the following link is the proposal FOR developing
> the Directive, not the
> actual draft itself.
> http://europa.eu.int/comm/environment/docum/00347_en.htm
>
> Does anyone have a link to the actual draft Directive? What is the
proposed
> implementation
> date?
>
> Thanks.
>
> John Juhasz
> Fiber Options
> Bohemia, NY
>
> ---
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Re: WEEE Directive

[JRadomski]

John,

Try this:

http://europa.eu.int/eur-lex/en/com/dat/2000/en_500PC0347_01.html

John Radomski




 
John Juhasz 
 
  
om>   cc:   
 
Sent by:  Subject:     WEEE Directive   
 
owner-emc-pstc@majordom 
 
o.ieee.org  
 

 

 
12/06/01 04:38 PM   
 
Please respond to John  
 
Juhasz  
 

 

 






I am trying to find a link to the draft of the actual WEEE (Waste
Electrical
and Electronic Equipment) Directive.
What I found thus far at the following link is the proposal FOR developing
the Directive, not the
actual draft itself.
http://europa.eu.int/comm/environment/docum/00347_en.htm

Does anyone have a link to the actual draft Directive? What is the proposed
implementation
date?

Thanks.

John Juhasz
Fiber Options
Bohemia, NY

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RE: WEEE Directive

[Allen, John]

John & Friends

For the draft directives, see

http://europa.eu.int/eur-lex/en/com/dat/2000/en_500PC0347_01.html

Can't help with the date.

Regards


John Allen

-Original Message-
From: John Juhasz [mailto:jjuh...@fiberoptions.com]
Sent: 06 December 2001 21:39
To: 'emc-p...@ieee.org'
Subject: WEEE Directive




I am trying to find a link to the draft of the actual WEEE (Waste Electrical
and Electronic Equipment) Directive.
What I found thus far at the following link is the proposal FOR developing
the Directive, not the
actual draft itself.
http://europa.eu.int/comm/environment/docum/00347_en.htm

Does anyone have a link to the actual draft Directive? What is the proposed
implementation
date?

Thanks.

John Juhasz
Fiber Options
Bohemia, NY

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WEEE Directive

[John Juhasz]

I am trying to find a link to the draft of the actual WEEE (Waste Electrical
and Electronic Equipment) Directive.
What I found thus far at the following link is the proposal FOR developing
the Directive, not the
actual draft itself.
http://europa.eu.int/comm/environment/docum/00347_en.htm

Does anyone have a link to the actual draft Directive? What is the proposed
implementation
date?

Thanks.

John Juhasz
Fiber Options
Bohemia, NY

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RE: Draft WEEE Directive - BeCu

[WOODS]

The latest draft of the proposed directive on hazardous substances in
equipment is 2000/C 365 E/13 published in the OJ on 19.12.2000.  It lists
lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB)
and polybrominated diphenyl ether (PBDE). These would be banned from 1
January 2008 with some listed exceptions for certain applications of lead,
mercury, cadmium and hexavalent chromium.


Richard Woods

--
From:  Gary McInturff [SMTP:gary.mcintu...@worldwidepackets.com]
Sent:  Tuesday, January 30, 2001 5:14 PM
To:  emc-p...@majordomo.ieee.org
Subject:  Draft WEEE Directive - BeCu


Trying to identify if beryllium-copper is controlled or Banned in
Europe. Looked at the waste directive (4th edition) and didn't see a
reference to it. Anybody have an information on it (or did I either just
miss it or am I looking at the wrong place?)
Thanks
Gary

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RE: Draft WEEE Directive - BeCu

[Tudor, Allen]

I was recently told by a representative of Instrument Specialties that
beryllium-copper is no longer banned in Europe.  I can provide a name and
number if you need it.

-Original Message-
From: Gary McInturff [mailto:gary.mcintu...@worldwidepackets.com]
Sent: Tuesday, January 30, 2001 5:14 PM
To: emc-p...@majordomo.ieee.org
Subject: Draft WEEE Directive - BeCu



Trying to identify if beryllium-copper is controlled or Banned in
Europe. Looked at the waste directive (4th edition) and didn't see a
reference to it. Anybody have an information on it (or did I either just
miss it or am I looking at the wrong place?)
Thanks
Gary

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Draft WEEE Directive - BeCu

[Gary McInturff]

Trying to identify if beryllium-copper is controlled or Banned in
Europe. Looked at the waste directive (4th edition) and didn't see a
reference to it. Anybody have an information on it (or did I either just
miss it or am I looking at the wrong place?)
Thanks
Gary

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Re: WEEE directive (4th Draft)

[Art Michael]

Hello Richard,

The official EU version (in .pdf format) was mounted on the net only this
morning. 

Visit the Safety Link , drop down to the "Safety
Articles, FAQs, MRAs, Etc." subsection; look for "WEEE" towards the end of
the section. 

Or, once you enter the Safety Link, use your browser's "Find"  or "Search"
function to locate the term "WEEE". 

Regards, Art Michael

Int'l Product Safety News
A.E. Michael, Editor
166 Congdon St. East
P.O. Box 1561 
Middletown CT 06457 U.S.A.

Phone  :  (860) 344-1651
Fax:  (860) 346-9066
Email  :  i...@connix.com
Website:  http://www.safetylink.com
ISSN   :  1040-7529
-


On Mon, 12 Jun 2000 wo...@sensormatic.com wrote:

> 
> It has been reported that the 4th draft directive on Waste Electrical and
> Electronic Equipment (WEEE) was set to be "approved" the first week in June
> although it must go through the European Parliament before final adoption.
> 
> Does anyone know if this draft is available on the web? I was unsuccessful
> in finding it.
> 
> Richard Woods
> 
> ---
> This message is from the IEEE EMC Society Product Safety
> Technical Committee emc-pstc discussion list.
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> 
> 
> 



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FW: 4th Draft WEEE Directive on Web

[WOODS]

See below. However, I learned yesterday that the Commission has decided to
now have two directives, one of which will cover design of equipment and the
other will cover the recovery process.

Richard Woods

--
From:  Roger Viles [SMTP:roger.vi...@wwgsolutions.com]
<mailto:[SMTP:roger.vi...@wwgsolutions.com]> 
Sent:  Thursday, June 15, 2000 10:09 AM
To:  wo...@sensormatic.com <mailto:wo...@sensormatic.com> 
Subject:  $th Draft WEEE Directive on Web

Richard,

I have not re-subscribed so please can you post this if you think others
are interested. ICER in UK have the 4th draft from May 2000 on their
website:  http://www.icer.org.uk/legislation/draftdir4.htm
<http://www.icer.org.uk/legislation/draftdir4.htm>  but this does
not include the introductory sections. For the full version see
http://www.pcfab.com/weee/WEEE4draft10_5_00.pdf
<http://www.pcfab.com/weee/WEEE4draft10_5_00.pdf> 
Hope this helps,

Roger




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WEEE directive

[WOODS]

It has been reported that the 4th draft directive on Waste Electrical and
Electronic Equipment (WEEE) was set to be "approved" the first week in June
although it must go through the European Parliament before final adoption.

Does anyone know if this draft is available on the web? I was unsuccessful
in finding it.

Richard Woods

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RE: WEEE Directive

[Robert Tims (EMX)]

Actually, Gentlemen,

PVC compounds are doped with many different types of flame retardants. In
fact, every plastic material must be doped with flame retardants to be flame
retardant, because plastics are made from petroleum.
However, there are PVC materials that that use flame retardants that when
exposed to flame, produce water (steam) and CO2 as by-products, thus robbing
the plastic of heat and oxygen. These hydroxy-doped PVC's are commercially
available by all the big PVC manufacturers, and the cable manufacturers
worth their salt all have product lines based on these PVC materials for
insulation and jacket materials. 
All this aside, also remember  that while these Hydroxy-retardant PVCs
reduce greatly the halogenated by-products from combustion, PVC is still
Poly-vinyl Chloride... Also look into Flame retardant Polyolefins (FRPE,
FRPO) as basis for wires and cables, this is a good option for non-halogen
applications, just more expensive with less applications than PVC.

Good Luck. If you need any more info, you can contact me directly.

Regards,

Robert Tims
Compliance Engineer
Ericsson Messaging Systems Inc.


> -Original Message-
> From: Rich Nute [SMTP:ri...@sdd.hp.com]
> Sent: Tuesday, November 09, 1999 11:04 AM
> To:   wo...@sensormatic.com
> Cc:   emc-p...@majordomo.ieee.org
> Subject:  Re: WEEE Directive
> 
> 
> 
> 
> Hi Richard:
> 
> 
> >Are there currently
> any
> >   alternative wire and cable constructions that comply with UL and NEC
> flame
> >   requirements without the use of halogenated flame retardants?
> 
> I believe PVCs are "naturally" flame-retardant materials
> i.e., have no flame retardants added to them.  
> 
> Many commonly-used wire and cable insulations are PVC.
> 
> 
> Best regards,
> Rich
> 
> 
> 
> -
>  Richard Nute  Product Safety Engineer
>  Hewlett-Packard Company   Product Regulations Group 
>  AiO Division  Tel   :   +1 858 655 3329 
>  16399 West Bernardo Drive FAX   :   +1 858 655 4979 
>  San Diego, California 92127   e-mail:  ri...@sdd.hp.com 
> -
> 
> 
> 
> 
> -
> This message is coming from the emc-pstc discussion list.
> To cancel your subscription, send mail to majord...@ieee.org
> with the single line: "unsubscribe emc-pstc" (without the
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> roger.volgst...@compaq.com (the list administrators).
> 
> 


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Re: WEEE Directive

[Darrell Locke (MSMail)]

One problem is with "retractile" type jacketed cables (used for coiled
cables).  PVC just doesn't work.  These are usually polyurethane, which have
traditionally used halogen-based flame retardants.  There are some
non-halogenated compounds available.  BF Goodrich for instance, produces a
product called ESTANE that has a non-halogen flame retardant.  You should
specify the jacket material on the cable drawing or you will likely get a
halogen flame retardant for polyurethane cables.

Darrell Locke
Advanced Input Devices
 --
From: Rich Nute
To: wo...@sensormatic.com
Cc: emc-p...@majordomo.ieee.org
Subject: Re: WEEE Directive
List-Post: emc-pstc@listserv.ieee.org
Date: Tuesday, November 09, 1999 8:03AM




Hi Richard:


>Are there currently any
>   alternative wire and cable constructions that comply with UL and NEC
flame
>   requirements without the use of halogenated flame retardants?

I believe PVCs are "naturally" flame-retardant materials
i.e., have no flame retardants added to them.

Many commonly-used wire and cable insulations are PVC.


Best regards,
Rich



 -
 Richard Nute  Product Safety Engineer
 Hewlett-Packard Company   Product Regulations Group
 AiO Division  Tel   :   +1 858 655 3329
 16399 West Bernardo Drive FAX   :   +1 858 655 4979
 San Diego, California 92127   e-mail:  ri...@sdd.hp.com
 -




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Re: WEEE Directive

[Rich Nute]

Hi Richard:


>Are there currently any
>   alternative wire and cable constructions that comply with UL and NEC flame
>   requirements without the use of halogenated flame retardants?

I believe PVCs are "naturally" flame-retardant materials
i.e., have no flame retardants added to them.  

Many commonly-used wire and cable insulations are PVC.


Best regards,
Rich



-
 Richard Nute  Product Safety Engineer
 Hewlett-Packard Company   Product Regulations Group 
 AiO Division  Tel   :   +1 858 655 3329 
 16399 West Bernardo Drive FAX   :   +1 858 655 4979 
 San Diego, California 92127   e-mail:  ri...@sdd.hp.com 
-




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WEEE Directive

[WOODS]

The current draft of the proposed European Union Directive on Waste and
End-of-life Electronic Equipment calls for the phase-out of the use of
halogenated flame retardants by January 1, 2004. Are there currently any
alternative wire and cable constructions that comply with UL and NEC flame
requirements without the use of halogenated flame retardants?

Richard Woods

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RE: WEEE Directive

[Dieker, Paris]

I guess some members of this group will interested to know that there are
quite some lobbing activities underway.
Here is a position paper from AEA (American Electronic Association)
http://www.svtc.org/svtc/cleancc/weeeaea.htm and EUROBIT
http://www.eurobit.org/pages/EUROBIT/POSITION/Pos032.html based on the
second draft. 

As far as I know in the meantime the Commission (DG-XI) have issued a third
draft (dated 5 July 1999) of the WEEE Directive in seven parts, which I
heard is fairly similar to the second draft but did not take any of the
industry's  lobbying comments (see above links) into account.

Regards,
Paris Dieker

Compaq Computer EMEA B.V.
Einsteinring 30, 85609 Dornach, Germany
T: +49 (0)89 9392-2332
F: +49 (0)89 9392-2336
eMail: paris.die...@compaq.com



-Original Message-
From: POWELL, DOUG [mailto:doug.pow...@aei.com]
Sent: Thursday, August 05, 1999 20:26
To: 'Crabb, John'; 'EMC-PSTC (E-mail)'
Subject: RE: WEEE Directive



John,

Eventually I did find that symbol on the EUR-LEX Legislation in Force web
pages.   When I saw the symbol it surprised me that they did not use the
circle-bar logo over the trash bin.

This directive does concern us as it deals with more than just heavy metals
and the 2nd draft of the proposal indicates that the manufacturer may need
to provide free recycling services.  My understanding is that the content of
this draft is based partly on the German "Blue Angel" mark, Scandinavian
"Nordic Swan" and the EU's "Eco-Label".

-doug


-Original Message-
From: Crabb, John [mailto:jo...@exchange.scotland.ncr.com]
Sent: Thursday, August 05, 1999 3:34 AM
To: 'EMC-PSTC (E-mail)'
Subject: RE: WEEE Directive



Doug, I would have thought you would already have come across the
symbol for the "crossed-out wheeled bin" in the directive 93/86/EEC
which "adapts to technical progress Council Directive 91/157/EEC
on batteries and accumulators containing certain dangerous substances",
the dangerous substances being lead, cadmium, and mercury.

The WEEE directive is a real "bag of worms" - it bans the use of lead 
based solder for a start !
I'm afraid I haven't been following the progress of  this particular
directive
very diligently, since it is really "environmental" rather than "safety",
but
there is certainly a lot of criticism from industry flying around.
John Crabb, Development Excellence (Product Safety) , 
NCR  Financial Solutions Group Ltd.,  Kingsway West, Dundee, Scotland. DD2
3XX
E-Mail :john.cr...@scotland.ncr.com
Tel: +44 (0)1382-592289  (direct ). Fax +44 (0)1382-622243.   VoicePlus
6-341-2289.


> -Original Message-
> From: POWELL, DOUG [SMTP:doug.pow...@aei.com]
> Sent: 03 August 1999 01:01
> To:   EMC-PSTC (E-mail)
> Subject:  WEEE Directive
> 
> 
> Hello group,
> 
> This may be off-topic, then again it maybe not.  It is regulatory for
> electronic equipment.
> 
> I currently have a copy of the second draft of the "Proposal for a
> directive
> on waste from electrical and electronic equipment".  Now I have done a
> fair
> amount of searching about this and located a number of pages to review on
> the Eur-Lex website.  But I still am not sure what the impact is for my
> company.  It appears that manufacturers will eventually be required to
> provide a free service for recycling their obsolete products.
> 
> Does anyone know if and when this goes into force.  And if this comes
> about
> what are the implications to manufacturers who import their products into
> the European Community.  What is the appearance of this symbol described
> as
> a "crossed-out wheeled bin"?  What notifications are required in user
> documentation?  Is there a requirement to either provide or contract
> recycling centers?
> 
> Thanks for any help,
> 
> -doug
> 
> ===
> Douglas E. Powell, Compliance Engineer
> Advanced Energy Industries, Inc.
> Fort Collins, Colorado 80525 USA
> ---
> 970-407-6410  (phone)
> 970-407-5410  (e-fax)
> mailto:doug.pow...@aei.com <mailto:doug.pow...@aei.com> 
> http://www.advanced-energy.com <http://www.advanced-energy.com/> 
> ===
> 

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Re: Weee Directive

[roger . viles]

Summary info about the WEEE Directive, relevant also to the California warning
notice required for lead content.

Producer takes responsibility for pollution
Compulsory targets by Jan 2006
target of 70% recycling or re-use by 2004
5% reuse of plastics in new products by 2004
Ban on lead, cadmium, etc by 1 Jan 2004. This includes a ban on lead solder!

You can get the draft directive, and read the American Electronics Association
(AEA)'s position on it, at:
http://www.svtc.org/cleancc/weeeaea.htm

Roger Viles
WWG





"Brian Harlowe"  on 05/08/99 17:18:40

Please respond to "Brian Harlowe" 

To:   emc-p...@ieee.org
cc:(bcc: Roger Viles/PLY/Global)

Subject:  Weee Directive






Like John Crabb I am not too well informed regarding this directive.

I believe though that the bare bones of it is that by the year 200*
ALL electronic equipment must be able to be recycled. I believe I saw
something where this will be phased in where a certain percentage of
the unit will have to comply but the ultimate aim is to achieve total
recycling.

This has started in a limited fashion in the UK there are now
companies being set up to dismantle old PCs and other units and
recycle the plastic housings and the CRTs and other components.

As I say my knowledge is thin but I do have some info in an ERA
Safety and EMC newsletter that I will fax to any one if they want it.

Regards

Brian Harlowe
* opinions expressed here are personal and in no way reflect the position of VG
Scientific
* opinions expressed here are personal and in no way reflect the position of VG
Scientific

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RE: WEEE Directive

[POWELL, DOUG]

John,

Eventually I did find that symbol on the EUR-LEX Legislation in Force web
pages.   When I saw the symbol it surprised me that they did not use the
circle-bar logo over the trash bin.

This directive does concern us as it deals with more than just heavy metals
and the 2nd draft of the proposal indicates that the manufacturer may need
to provide free recycling services.  My understanding is that the content of
this draft is based partly on the German "Blue Angel" mark, Scandinavian
"Nordic Swan" and the EU's "Eco-Label".

-doug


-Original Message-
From: Crabb, John [mailto:jo...@exchange.scotland.ncr.com]
Sent: Thursday, August 05, 1999 3:34 AM
To: 'EMC-PSTC (E-mail)'
Subject: RE: WEEE Directive



Doug, I would have thought you would already have come across the
symbol for the "crossed-out wheeled bin" in the directive 93/86/EEC
which "adapts to technical progress Council Directive 91/157/EEC
on batteries and accumulators containing certain dangerous substances",
the dangerous substances being lead, cadmium, and mercury.

The WEEE directive is a real "bag of worms" - it bans the use of lead 
based solder for a start !
I'm afraid I haven't been following the progress of  this particular
directive
very diligently, since it is really "environmental" rather than "safety",
but
there is certainly a lot of criticism from industry flying around.
John Crabb, Development Excellence (Product Safety) , 
NCR  Financial Solutions Group Ltd.,  Kingsway West, Dundee, Scotland. DD2
3XX
E-Mail :john.cr...@scotland.ncr.com
Tel: +44 (0)1382-592289  (direct ). Fax +44 (0)1382-622243.   VoicePlus
6-341-2289.


> -Original Message-
> From: POWELL, DOUG [SMTP:doug.pow...@aei.com]
> Sent: 03 August 1999 01:01
> To:   EMC-PSTC (E-mail)
> Subject:  WEEE Directive
> 
> 
> Hello group,
> 
> This may be off-topic, then again it maybe not.  It is regulatory for
> electronic equipment.
> 
> I currently have a copy of the second draft of the "Proposal for a
> directive
> on waste from electrical and electronic equipment".  Now I have done a
> fair
> amount of searching about this and located a number of pages to review on
> the Eur-Lex website.  But I still am not sure what the impact is for my
> company.  It appears that manufacturers will eventually be required to
> provide a free service for recycling their obsolete products.
> 
> Does anyone know if and when this goes into force.  And if this comes
> about
> what are the implications to manufacturers who import their products into
> the European Community.  What is the appearance of this symbol described
> as
> a "crossed-out wheeled bin"?  What notifications are required in user
> documentation?  Is there a requirement to either provide or contract
> recycling centers?
> 
> Thanks for any help,
> 
> -doug
> 
> ===
> Douglas E. Powell, Compliance Engineer
> Advanced Energy Industries, Inc.
> Fort Collins, Colorado 80525 USA
> ---
> 970-407-6410  (phone)
> 970-407-5410  (e-fax)
> mailto:doug.pow...@aei.com <mailto:doug.pow...@aei.com> 
> http://www.advanced-energy.com <http://www.advanced-energy.com/> 
> ===
> 

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Weee Directive

[Brian Harlowe]

Like John Crabb I am not too well informed regarding this directive.

I believe though that the bare bones of it is that by the year 200* 
ALL electronic equipment must be able to be recycled. I believe I saw 
something where this will be phased in where a certain percentage of 
the unit will have to comply but the ultimate aim is to achieve total 
recycling.

This has started in a limited fashion in the UK there are now 
companies being set up to dismantle old PCs and other units and 
recycle the plastic housings and the CRTs and other components.

As I say my knowledge is thin but I do have some info in an ERA 
Safety and EMC newsletter that I will fax to any one if they want it.

Regards

Brian Harlowe
* opinions expressed here are personal and in no way reflect the position of VG 
Scientific
* opinions expressed here are personal and in no way reflect the position of VG 
Scientific

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RE: WEEE Directive

[Crabb, John]

Doug, I would have thought you would already have come across the
symbol for the "crossed-out wheeled bin" in the directive 93/86/EEC
which "adapts to technical progress Council Directive 91/157/EEC
on batteries and accumulators containing certain dangerous substances",
the dangerous substances being lead, cadmium, and mercury.

The WEEE directive is a real "bag of worms" - it bans the use of lead 
based solder for a start !
I'm afraid I haven't been following the progress of  this particular
directive
very diligently, since it is really "environmental" rather than "safety",
but
there is certainly a lot of criticism from industry flying around.
John Crabb, Development Excellence (Product Safety) , 
NCR  Financial Solutions Group Ltd.,  Kingsway West, Dundee, Scotland. DD2
3XX
E-Mail :john.cr...@scotland.ncr.com
Tel: +44 (0)1382-592289  (direct ). Fax +44 (0)1382-622243.   VoicePlus
6-341-2289.


> -Original Message-
> From: POWELL, DOUG [SMTP:doug.pow...@aei.com]
> Sent: 03 August 1999 01:01
> To:   EMC-PSTC (E-mail)
> Subject:  WEEE Directive
> 
> 
> Hello group,
> 
> This may be off-topic, then again it maybe not.  It is regulatory for
> electronic equipment.
> 
> I currently have a copy of the second draft of the "Proposal for a
> directive
> on waste from electrical and electronic equipment".  Now I have done a
> fair
> amount of searching about this and located a number of pages to review on
> the Eur-Lex website.  But I still am not sure what the impact is for my
> company.  It appears that manufacturers will eventually be required to
> provide a free service for recycling their obsolete products.
> 
> Does anyone know if and when this goes into force.  And if this comes
> about
> what are the implications to manufacturers who import their products into
> the European Community.  What is the appearance of this symbol described
> as
> a "crossed-out wheeled bin"?  What notifications are required in user
> documentation?  Is there a requirement to either provide or contract
> recycling centers?
> 
> Thanks for any help,
> 
> -doug
> 
> ===
> Douglas E. Powell, Compliance Engineer
> Advanced Energy Industries, Inc.
> Fort Collins, Colorado 80525 USA
> ---
> 970-407-6410  (phone)
> 970-407-5410  (e-fax)
> mailto:doug.pow...@aei.com <mailto:doug.pow...@aei.com> 
> http://www.advanced-energy.com <http://www.advanced-energy.com/> 
> ===
> 

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RE: WEEE Directive

[Jody Leber]

Doug,

Try contacting Chris Robertson of ERA

chris.robert...@era.co.uk

44 0 1372 367134

or

Graham Adams of Motorola

44 0 1462 731580

Both of these individuals have written articles on the subject.  I believe the 
proposed date is January 1, 2004.

Best Regards,

Jody Leber

jle...@ustech-lab.com
http://www.ustech-lab.com

U. S. Technologies
3505 Francis Circle
Alpharetta, GA 30004

770.740.0717
Fax:  770.740.1508

-Original Message-
From:   POWELL, DOUG [SMTP:doug.pow...@aei.com]
Sent:   Monday, August 02, 1999 8:01 PM
To: EMC-PSTC (E-mail)
Subject:WEEE Directive


Hello group,

This may be off-topic, then again it maybe not.  It is regulatory for
electronic equipment.

I currently have a copy of the second draft of the "Proposal for a directive
on waste from electrical and electronic equipment".  Now I have done a fair
amount of searching about this and located a number of pages to review on
the Eur-Lex website.  But I still am not sure what the impact is for my
company.  It appears that manufacturers will eventually be required to
provide a free service for recycling their obsolete products.

Does anyone know if and when this goes into force.  And if this comes about
what are the implications to manufacturers who import their products into
the European Community.  What is the appearance of this symbol described as
a "crossed-out wheeled bin"?  What notifications are required in user
documentation?  Is there a requirement to either provide or contract
recycling centers?

Thanks for any help,

-doug

===
Douglas E. Powell, Compliance Engineer
Advanced Energy Industries, Inc.
Fort Collins, Colorado 80525 USA
---
970-407-6410  (phone)
970-407-5410  (e-fax)
mailto:doug.pow...@aei.com <mailto:doug.pow...@aei.com> 
http://www.advanced-energy.com <http://www.advanced-energy.com/> 
===



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WEEE Directive

[POWELL, DOUG]

Hello group,

This may be off-topic, then again it maybe not.  It is regulatory for
electronic equipment.

I currently have a copy of the second draft of the "Proposal for a directive
on waste from electrical and electronic equipment".  Now I have done a fair
amount of searching about this and located a number of pages to review on
the Eur-Lex website.  But I still am not sure what the impact is for my
company.  It appears that manufacturers will eventually be required to
provide a free service for recycling their obsolete products.

Does anyone know if and when this goes into force.  And if this comes about
what are the implications to manufacturers who import their products into
the European Community.  What is the appearance of this symbol described as
a "crossed-out wheeled bin"?  What notifications are required in user
documentation?  Is there a requirement to either provide or contract
recycling centers?

Thanks for any help,

-doug

===
Douglas E. Powell, Compliance Engineer
Advanced Energy Industries, Inc.
Fort Collins, Colorado 80525 USA
---
970-407-6410  (phone)
970-407-5410  (e-fax)
mailto:doug.pow...@aei.com  
http://www.advanced-energy.com  
===



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