Everything EEE
The new RoHS directive is expected to cover all but a very few instances of Electrical and Electronic Equipment (EEE). Annex I of the directive introduces a new, eleventh product category – ‘other electrical and electronic equipment not covered by any of the categories above (categories 1–10).’ Thus electrical and electronic equipment types that were not covered before will be covered by RoHS II, including formerly grey zone items such as electric toys.
Product exemptions from categories 8 and 9 are to be gradually phased out, including medical devices (three years after RoHS II publication, category 8), in-vitro diagnostics (five years after RoHS II publication, category 8), control and monitoring devices (three years after RoHS II publication, category 9), industrial control and monitoring instruments (six years after RoHS II publication, category 9).
RoHS II Exemptions
In its current draft form, RoHS II exempts ten types of electrical and electronic equipment: equipment pertaining to the security and protection of Member States, including arms, munitions and war materials intended specifically for military use; equipment designed to be sent into space; equipment designed for installation as part of equipment that is exempt from the directive, specifically if the equipment is only for use in exempt equipment and can only be replaced by equipment of the exact same design; large scale stationary industrial tools; large scale fixed installations; transport means for persons or goods, excluding electric two wheel vehicles that are not type approved; mobile machinery unintended for road use that is available exclusively for professional use; active implantable medical devices; photovoltaic panels intended for use in a system that is designed, assembled and installed by professionals for permanent use at a specific location for the production of energy from solar light for public, commercial, industrial or residential use; equipment designed solely for the purposes of research and development and for utilization on a strictly business-to-business basis.
Besides these general exempt EEE there are still some specific exemptions of restricted substances in specific applications. Annex III and Annex IV define where otherwise restricted substances may be applied. It is noteworthy that in the future exemptions will have an expiration date. Interested parties have to make sure to re-apply for pro-longing exemptions in due time.
What Defines ‘Homogeneous Material’?
Previous definition of homogeneous materials for use by interested parties was adapted from the Technical Advisory Committee. RoHS II, however, seeks to introduce a definition of ‘homogeneous material’ which it states as being: ‘One material of uniform composition throughout or a material, consisting of a combination of materials, that cannot be mechanically disjointed into different materials, meaning that the materials cannot be separated by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes.’
Nothing New Under RoHS II
RoHS II introduces no new restricted substances. What it does, however, is to introduce a simplified mechanism for the review and amendment of the restricted substances list in the future. Substances highlighted for future review include: hexabromocyclododecane (HBCDD), phthalates (DEHP, BBP, DBP) and nanomaterials.
In order to enforce coherence with REACH legislation, a process for the exemption of substances has been introduced, with exemptions to be granted for periods of five to seven years, depending on product category. Annex III of RoHS II gives an updated list of all exempt substances in all electric and electronic equipment, while Annex IV features the exemptions relevant to category 8 and 9 products. To investigate the list and limits of all restricted substances, review is recommended of the annexes of the new directive (http://www.europarl.europa.eu/sides/getDoc.do?type=TA&language=EN&reference=P7-TA-2010-0431#BKMD-6 ).
RoHS II will be a CE Mark Directive
RoHS II is set to become a CE Mark directive, which means that CE marking will be affixed to all finished products, as per Module A of Annex II of 768/2008/CE. With CE marking (http://www.ee.sgs.com/ce-marking.htm ), the responsibility is now to be shared between manufacturers and importers and distributors. CE declaration remains the manufacturer’s obligation, while the release of compliant products onto the EU market becomes the responsibility of importers and distributors. The CE mark will now not only mean that an electrical or electronic product complies with all applicable regulations – for example, the low voltage directive or the electromagnetic compatibility requirement – the CE mark will also mean compliance with RoHS. Thus product compliance and conformity assessment will now include the obligation to comply with RoHS. If RoHS compliance is not assured, the application of the CE mark will violate EU law.
Formal adoption of RoHS II by the European Council is expected in the first quarter of 2011, with the directive becoming mandatory legislation 20 days after publication in the Official Journal of the European Union. At that point, member states have eighteen months to enforce the directive into law. Until that happens, the current RoHS directive 2002/95/EC remains in force. It needs to be considered though that some EU member states may have national laws in place which will automatically enforce updates of directive 2002/95/EC.
SGS can help ensure compliance with RoHS II and its global restricted substances service (http://www.ee.sgs.com/global-rohs-services.htm) enables full support of products with REACH, SHVC and other relevant international, national and regional regulations and legislation. SGS can also provide compliance assessment, which is essential for the preparation of the CE declaration of conformity.
For further details please contact:
SGS Consumer Testing Services
Dr. Udo Krischke
Global Technical Manager RSTS
Im Maisel 14, 65232 Taunusstein, Germany
t: +49 6128 744 235
E-mail: udo.krischke@sgs.com
Website: http://www.ee.sgs.com
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