Directive Decoder

Article 2.2 was discussed recently at the 3^rd Stakeholder meeting of the RoHS Impact Assessment in Brussels.

Article 2.2 states that equipment added to scope as a result of the RoHS Recast (2011/65/EU) can be "made available" in the European Union until 22 July 2019. This means that any such products cannot be sold, leased, loaned or given away after this date, including second hand or hire equipment,  if they contain RoHS restricted substances.

Looking on the radar this will affect category 8 and 9 products that will fall in to scope from various dates starting in July 2014.

Thanks to Dr Paul Goodman of ERA Technology.

Directive Decoder

In March 2007 the so called "Phase 1" of China RoHS, which focused on labelling and information requirements was implemented. This was to be followed later in 2007 by the publication of a China RoHS catalogue of products which could potentially be restricted.

Since then, information on the status has been scarce, although a move to "RoHS2" where China RoHS would have greater alignment with EU RoHS was talked about.

However, after extensive research we can confirm that little or no progress has been made and the only China RoHS legislation in existence at this time requires labelling of Electronic Information Products (EIPs).

Directive Decoder

We receive many questions around the status of various cables in respect to the RoHS Recast.

This sits with the RoHS Frequently Ask Question committee at present to provide guidance.

Their opinion is that HDMI, USB and AV cables and the like are finished Electrical and Electronic Equipment (EEE) and so should be CE marked and a Declaration of Conformity (DoC) provided.

It seems that all European Member States agree on this.

However, come manufacturers are unhappy with this and are lobbying for changes, but it is likely that these types of cable connector will always be regarded as finished EEE.

With thanks to Dr Paul Goodman of ERA Technology

Directive Decoder

"You need to consider it is a finished product because it is sold to end-users who use it as a complete and finished product. The lack of an enclosure does not mean it is not finished. Most European Union Member States (Enforcement Authorities) regard plug-in PCBs for PCs as finished products".

Those were the words that started the race against time to achieve compliance for the Raspberry Pi uncased Model B.

Continue reading "Raspberry Pi - the road to compliance" »

In March 2007 the first phase of the China RoHS legislation known as the Administration of the Control of Pollution (caused) by Electronic Information Products (EIPs) was implemented.

This was known as the "Declaration" stage and included the labelling of over 1800 EIPs.

A green symbol indicated that no restricted substances where present above permitted levels. The six substances aligned with the EU RoHS Directive as did the maximum concentration values.

The second symbol, that was typically, although not obligatory, orange was specified as the hazardous substance symbol were the product contained a substance, or substances, that were above the permitted values. The orange symbol also had to include the Environmentally Friendly (safe use) Period, or EFUP, in years. This was the period of time that it was safe to use the equipment before hazardous substances could leak out into the environment. A mobile phone, for example, might be 10 years.

Continue reading "China RoHS 2007-2012" »

In response to recent questions here is so more information around compliance aspects of the Raspberry Pi uncased Model B.

The board underwent EMC testing which enables one to discern if it should be classed A or B. From pre-compliance testing (RPi) it was evident that the board would not meet Class B. It did not meet the Class B limit but did meet, and comply with, the Class A limit.

It is legally acceptable to place Class A equipment on the market for use in a domestic environment in both the EU and U.S. and to affix the CE and FCC marks provided that a warning is provided on the product that it may cause interference. In respect of the RPi the warning is on the Safety Data Sheet.

Directive Decoder

Continue reading "RPi Class A and B" »

Decision 2012/48/EU extends the validity of 2009/251/EC requiring Member States to ensure that products containing the biocide dimethylfumarate (DMF) are not placed or made available on the market.

Many of you will remember the problems caused by DMF that was used to stop mould in sofas during transportation from China. This often resulted in a horrific rash which lead to peeling skin. DMF was also found in shoes.

However, there is a proposed restriction of DMF under Annex XVII of the REACH Regulations that was put forward by France and accepted by Member States. It is only a matter of time until the restriction is published in the Official Journal of the European Union at takes effect.

Article 1 of 2012/48/EU states that the decision shall apply until entry into force of the Commission Regulation amending Annex XVII  number 1907/2006 (REACH) concerning DMF or 15 March 2013, whichever is the earlier.

Directive Decoder

So, amid great excitement, the Raspberry Pi Model B - uncased version completed vigorous compliance tests late last week and the first products were finally despatched in the last few days.

The safety information sheet refers to compliance with EMC (Class A) CE, FCC, C-tick, WEEE, ESD and China. The launch was delayed about a month while essential tests were carried out.

Although not the view of everyone these open PCBs are considered "finished equipment" by the authorities and required such obligatory analysis.

RoHS compliance testing was undertaken, and while traces of cadmium and bromine could be found, they were within permitted values. The Pi was considered low risk in respect of REACH Substances of Very High Concern.

These boards will now be distributed all over the world.

Directive Decoder

Continue reading "The Pi is ready" »

Unless you have been on holiday on another planet no doubt you will be aware of the popular debate on whether or not an open PCB, with no case, can be considered finished equipment.

Product can be considered finished if it is sold to end-users who use it as a complete and finished product. The lack of an enclosure does not mean it isn't finished.

Most EU Member State authorities regard plug-in PCBs for PCs as finished products.

Directive Decoder

One of the requirements of the EU Batteries and Accumulators Directive 2006/66/EC was the need for Producers to ensure that any automotive or portable batteries, placed on the market, should display a capacity label by 26 September 2009.

BIS recently confirmed that this deadline had been extended and producers of rechargeable portable batteries and automotive batteries must display a capacity marking by 31 May 2012.

Batteries placed on the market prior to this date do not have to be removed from sale and single use portable batteries are not included within the scope of this requirement.

European regulation number 1103/2010 was published on 29 November 2010 and covers producer requirements, exemptions, standards for measuring capacity, what information should be contained on the label and its minimum size and location.

The requirements will be enforced by the National Measurement Office (NMO).

It will be interesting to see which battery manufacturers, if any, will gain or lose market share.

Directive Decoder

Under the RoHS Recast the scope has changed from products that depend on electronic currents or electromagnetic fields to work properly and  now reads to fulfil at least one intended function.

However, under the WEEE Recast the definition remains unchanged.

Directive Decoder

Since 2006 there have been many unofficial RoHS symbols highlighting compliance.

From RoHS compliant, to lead-free to Pb-free, probably because there was no official symbol for European RoHS.

However, the RoHS Recast Directive 2011/65/EU dismisses all of those ad-hoc symbols in favour of the simple CE mark to demonstrate compliance.

Directive Decoder

Many of you will remember the original RoHS Frequently Ask Questions document that was published several years ago by the European Commission.

The RoHS Recast (RoHS2) FAQ document will seek to address many questions including, no doubt, the subject of CE mark requirements.

According to BIS Officials it should be available around June time and could well be a must not miss document.

 Directive Decoder

The European Commission has begun its work on the RoHS impact study being carried out on the Restriction of Hazardous Substances (RoHS) Directive (2011/65/EU)  in electrical and electronic equipment.

As part of this review the product scope is expected to be widened, including new product categories that were previously excluded. Examples would include:

Category 7-toys leisure and sports equipment now includes "toys with minor electrical function" such as talking teddy bears.

Continue reading "RoHS Recast - new products" »

The European Chemicals Agency ECHA has stated that the target, set by the European Commission, of having 136 Substances of Very High Concern (SVHCs) on the Candidate List by the end of 2012 is likely to be missed.

Currently there are 73 substances on the list but only 13 proposals expected to go forward for consultation around the end of February.

ECHA expects the number to be nearer the 100 mark by the end of the year.

Farnell has collected REACH information on around half a million products and found that approximately 0.5% of them contained an SVHC.

Directive Decoder

For an expert webinar check out "Export Controls within the EU" which is live on 6th March at 2PM.

Subject expert Trevor Wood looks at reasons behind having export controls, who makes the decisions behind the controls, which items are controlled and how, as well as other issues.

For simple registration follow the link:

Free Export Controls within the EU webinar

Directive Decoder

There has been some debate recently regarding what the long awaited China RoHS legislation will look like and how it will impact on European companies exporting their products into the region.

The latest step saw the Implementation Rules of Voluntary Certification on the Pollution Control of Electronic Information Products which was adopted on 25 August and entered into force on 1 November 2011.

Also adopted on 25 August 2011 was the circular on the list of Electronic Information Products requiring Voluntary Certification (first batch) and any associated exemptions.

Continue reading "China RoHS Voluntary Certication" »

If the REACH Regulations can help save lives as well as protect the environment then I am sure we would all endorse it wholeheartedly.

However, there is no doubt that REACH is a significant burden on industry. I can clearly remember an Official addressing a meeting of industry delegates and saying that REACH was "never meant to be a paper chase".

Well it's too late, despite the number of third party organisations offering to provide data on "thousands" of products.

Continue reading "Thousands of products, few SVHCs" »

On 19 December the European Chemicals Agency (ECHA) based in Finland added a further 20 Substances of Very High Concern (SVHC) to the Candidate List for authorisation taking the total to 73......see details below:

http://bit.ly/yWUR4V

Directive Decoder

A new task force, including former police detectives, will support the Environment Agency in its fight to close illegal waste sites.

Backed by £5M of funding over two years the new Crime Agency will employ 90 new members of staff according to the ENDS Report.

According to the Agency there are 594 illegal waste sites in England and Wales - 215 in the South East, 99 in Yorkshire and the North East and 83 in the North West. The remainder are in East Anglia, the Midlands, the South West and Wales.

The new task force will work with councils, police, HM Revenue and Customs and the Department for Work and Pensions to bring criminals to justice.

More power to their elbow I say!

Directive Decoder