Directive Decoder

Hello there, and welcome to my new weekly rambling on all things legislation, and the impact on our industry.
Recently, I have read through what seemed like endless documents on China RoHS. One tip though, while the internet is an obvious source of information, some of the older documents are now out of date, and certain details have changed, so beware.
As the world gradually comes to terms with the RoHS (Restriction of use of Certain Hazardous Substances) Directive that came into force across European Member States in July 2006, we now have new legislation to consider.

Stage one of the "Measures for Administration of the Pollution Control of Electronic Information Products" hereafter called "China RoHS!!" comes into effect on March 1st.
While core elements of the European legislation, such as the maximum permitted levels of restricted substances, remain the same, China RoHS contains several unique features.

Stage one, from March, is fundamentally about labelling products (from a comprehensive, but not exhaustive, list of Electronic Information Products or EIP's) correctly based on whether or not they contain any restricted substances. Stage two is when it really "kicks off" as a catalogue will list products that do have substance restrictions, and these are not necessarily limited to the six substances that form the basis of EU RoHS. This catalogue, exact release date still unknown, will also include details of any exemptions as well as the implementation date by product.

The scope of China RoHS is broader than the EU and includes product categories such as test equipment, medical, sub assemblies and electronic components that are not currently within the scope of EU RoHS.
Other differences include variable implementation dates, madatory inspection and testing as well as clearly marking the actual packaging with the appropriate symbol and words.
A disclosure table, in Chinese, indicating which substances are present, and where they can be located in a piece of equipment, is also a requirement.
Finally, an EFUP, or Environment Friendly Use Period, must be included as part of the symbol denoting hazardous substances are present. This represents the period, in years, during which any of the substances present will not leak out and cause environmental pollution.

Finally for now, if you build and ship products into China that feature in the catalogue, be ready to send a sample off for testing and analysis by one of the approved labs in China, as well as seeking CCC accreditation (China Compulsory Certification). The implementation date, in theory, will allow sufficient time to do this once the product appears in the catalogue.

That's enough on China RoHS for now but much more during coming weeks.

I look forward to receiving your thoughts on RoHS, WEEE, EuP, REACH, ATEX, the Battery Directive or anything else "Green" especially if you are a Design Engineer who has had to make process changes to accommodate any of the new legislation.

Directive Decoder

The UK's WEEE Directive is now, finally, up and running, with obligated "Producers" required to sign up to a compliance scheme by March 15th 2007.
The legislation requires the Producers - defined as the manufacturers, re-branders and / or importers of electrical equipment - to pay for the recovery and recycling of electrical items at their end-of-life and to ensure recycling targets are met from July 1st 2007. A compliance scheme can help them do this.

Data has to be submitted via the scheme that the Producer joins, pertaining to the weight of electrical items placed on the market in calendar year 2006. This is due by 15th March 2007.
All products placed on the market after April 1st 2007 have to be labelled with the crossed out wheelie bin symbol and company identifier.

So, how much does this cost?
Well, first of all the cost of joining any scheme, then the Environment Agency fee of:
£30 for non-VAT registered companies
£220 for VAT registered companies with a turnover of up to £1 million
£445 for VAT registered companies with a turnover in excess of £1million

So which scheme's could be considered?
For those with obligations in the business-to-business field (where the final user is a business rather than a householder) the scheme would be such as b2b Compliance.
For Producers with business-to-consumer obligations (where the final user is a householder) then REPIC are a leader in this field.

Carl Kruger, of b2b Compliance, who has addressed AFDEC members a couple of times on the complex subject of the UK WEEE Directive, has kindly agreed to make himself available to answer any last minute questions you may have regarding compliance schemes and / or alternative options.

You can contact Carl at b2b Compliance on ++(0)1691 676 124.

Directive Decoder

Hello everyone
I am often asked if a product compliant "by exemption" under EU RoHS will be excluded from China RoHS.
As mentioned previously, "The Catalogue", when published in China, will determine which products will have substance restrictions as well as indicating where any exemptions will apply.
It made me think that, for example, some Passive Components, compliant by exemption in the EU, may well contain restricted substances beyond the maximum permitted levels. In this case they will need to be marked with logo number two for China RoHS.

From March 1st all Electronic Information Products, or EIP's, will be subject to one of the following symbols:
Logo 1 is generally green, but can be any other prominent colour if it does not look sufficiently clear against the background of the product.
This logo demonstrates that the products do not contain any toxic or hazardous substances above the maximum permitted concentration values. The "e" in the middle of the logo stands for electrical, electronic and environmental, signifying green and environmentally friendly EIP's. The outer, curved arrows, form a circle, demonstrating that the product can be recycled at end-of-life and that it should not be discarded casually.

Logo 2 is normally orange, but again, can be any other prominent colour if there is a clash. Orange denotes caution, and indicates that the product does contain toxic or hazardous substances beyond the maximum permitted concentration values. The number in the middle of the logo highlights the environmental protection use period, often referred to as EFUP. The product can be used safely during this period. This is shown in individual years up to five, and then in multiples of five years thereafter.
The outer circle is again formed by curved arrows demonstrating that the EIP can be recycled once the environmental use period has expired.
A disclosure table showing which substances are present, and where they are located in the product, will aid the recycler.

If the size or function of the EIP prevents direct marking, then this can be included as part of the product indtructions.

I hope this has made the use of the logo's clearer but, as always, I look forward to receiving your observations, or questions, on this matter, or anything else relating to China RoHS.

Directive Decoder

REACH is an EU-wide reform of the regulatory environment in which chemicals are used. The aim is to improve the protection of human health and the environment through the better, and earlier, identification of the properties of chemical substances. A further benefit will be to enhance the innovative capability and competitiveness of the EU chemical industry.

REACH is intended to establish an integrated system for Registration, Evaluation and Authorisation of Chemicals. It extends the stringent testing which has been required for chemicals introduced since 1981 to those already in use (estimated at 30,000 substances).

The responsibility for providing sufficient information and taking effective risk management measures will lie principally with manufacturers or importers of chemicals. Obligations will also be introduced further down the supply chain particurlarly in terms of the safe use of chemicals.

In force from 1st June 2007, after publication in the European Commission's Official Journal on 30th December 2006, REACH runs to 849 pages and replaces over 40 other laws.
A series of deadlines then follow around pre-registration, by December 2008, immediately followed by a published list of pre-registered substances.
December 2010 will see the end of the first registration period for the most dangerous and / or higher volume substances.

There is no definitive list of chemicals which are likely to be covered by REACH. Chemicals are currently covered by the EINECS (European Inventory of Existing Commercial - chemical - Substances) list of 70,000 to 100,000 chemicals subject to pre 1981 legislation. This list is clearly out of date and many of the chemicals may no longer be on the market.
Chemicals subject to post 1981 legislation are covered by the EUCLID list. As mentioned, a new list will replace around 40 existing regulations. Implementation will be staggered so that the entire process will take about 11 years to complete.

I will cover topics such as obligations on manufacturers and importers, downstream users and issues for the electronics industry, including the supply chain, in a future rant.

If REACH has an impact on your business please drop me a line and tell me why, and what you are doing about it.

DIRECTIVE DECODER