Directive Decoder

As I continue my overview tour of various legislation I thought I would have a quick look at European Union Directive 94/9/EC commonly known as "ATEX".
Often asked what does it stand for (a great pub quiz question!!) it derives from the French "ATmosphere EXplosible" and covers electrical and non-electrical equipment that is used in potentially explosive atmospheres. Explosive atmospheres may be present where flammable solvents or combustable dusts, such as flour, are used. Flammable solvents may be used for cleaning or as an additive to a process.
Equipment that is used in these environments must be designed to avoid causing an explosion
or fire, i.e. avoid sparks and other ignition sources, and they cannot be put on the EU market until approved by a Notified Body who will issue a Certificate of Conformity.

There is another related directive called the ATEX 137 Workplace Directive 1999/92/EC (DSEAR-Dangerous Substances & Explosive Atmospheres Regulations - in the UK). This is concerned with the safety of the workplace and requires the user to carry out a risk assessment and mark hazardous areas according to risk. "Zones" are based on the risk level and relate to categories defined by the ATEX equipment directive. Both of these directives are currently in force in the EU.

ATEX is an EU Directive and equipment sold in other parts of the world may need to meet different local legislative requirements. In North America, for example, documentation is submitted to an appropriate approvals body and testing is also carried out. In the rest of the world, most countries use IEC Standards as national standards.

I will go deeper into ATEX during the coming weeks. If ATEX impacts your business I would love to hear from you.

Next up, I will have a look at the EuP (Energy using Products) Directive.

Directive Decoder

Hi all
Let us have a quick look at the EuP (Energy using Products) Directive which, it has been said by some commentators, may have an even more profound effect on industry than the RoHS Directive.
The objective of the EuP Directive is to bring about improvements in efficiency of energy using products throughout their life cycle. Its focus is on the design phase since it is considered that this is the determining stage affecting the resources used in a product.
The Directive does not apply to means of transport (aircraft, cars etc.) but, apart from this, the scope is deliberately broad, covering, in principle, any product which when in use depends on, generates, transfers or measures energy (electricity, fossil fuel or renewable).

Products that may well fall within scope include, for example:
Boilers and combi-boilers
Water heaters
PC's
Imaging equipment
Consumer electronics, such as televisions
Lighting (office and street)
Water pumps
Ventilation fans (non residential buildings)
Refrigerators and freezers
Dishwashers and washing machines

Certain criteria will have to be met to ensure that there is a real need and a benefit for each category to fall within scope.
A product must:
Sell more than 200,000 units per year in the EU
Have a significant environmental impact
Present significant potential for improvement

I will go into greater detail on how this will potentially work during the coming weeks. However, as far as component suppliers and distributors are concerned, EuP is going to mean a continuing pressure to remove restricted substances, and to reduce power consumption and weight. There will also be a growing demand for more comprehensive data on energy use, composition and compatibility of materials, weight, disassembley, recyclability, identification and in some cases a move towards modular designs which can be upgraded more easily.

Since EuP requires consideration of the whole life cycle in the context of price, performance and competitiveness, it is to be hoped that this will make for better design changes that are demonstrably beneficial in reducing environmental impact in ways that are not detrimental to commercial considerations. It remains to be seen if this optimistic prospect is realised.

If this directive has a potential impact on your business, please drop me a line.

Well, enough of EuP and, if that was a bit heavy for you, next stop on our tour is something we can all relate to.....The Battery Directive.

Directive Decoder

Hi all
15 years after the first Batteries and Accumulators Directive came into force the EU has adopted Directive 2006/66/EC which was published in September 2006 and comes into force in September 2008.
The new batteries directive will affect producers, importers and distributors of all types of batteries that are put onto the EU market either as individual batteries or incorporated within electrical equipment.
In practice all consumer or industrial batteries are in scope including NiCad batteries, car batteries, button cells (watches etc) as well as back-up power supplies.
The new directive does not apply to equipment specifically intended for military purposes or equipment designed to be sent into space.

The approach used for the battery directive has several similarities to WEEE and RoHS as it requires batteries to be collected at end of life and recycled (financed by Producers).
There are also substance restrictions and labelling requirements.

The use of mercury remains unchanged, including the exemption for button cells, from the earlier directive but a restriction on cadmium will be imposed from September 2008, other than in emergency and alarm systems (including lighting) medical equipment and cordless power tools. The latter is subject to review by the European Commission.

Batteries must be collected and, as such, schemes will be required to help end-users discard batteries easily. Collection targets for Member States are set at 25% of annual sales by 2012 and 45% by 2016.
Recycling targets are also imposed depending on the type of battery: lead acid = 65%, nickel- cadmium = 75% and others 50%. As much lead and cadmium must be recovered as is technically possible while avoiding excessive costs.

All batteries must be labelled with the crossed wheelie bin symbol (with certain exceptions) and with the chemical symbol for lead, cadmium or mercury if any of these are present.
Where batteries are incorporated into products, instructions showing how to remove them must be provided with the equipment.

More on this in future articles.

If this directive impacts your business, please drop me a line.

Directive Decoder

Further draft Guidance on the Environment Friendly Use Period (EFUP) highlights a few changes.
Previously the number of years within the orange logo, which indicates the product contains RoHS substances above the maximum permitted concentration values, ran in sequence 1,2,3,4,5 then in multiples of 5. It is now defined as increments of a year up to 10 years, then multiples of 5, up to 95.

You will remember that the EFUP is the period of time before any of the RoHS substances are likely to leak out, causing possible harm to health and the environment.
Some guide examples in the latest draft standard have also been amended. A cellphone is now "safe" for 10 years as opposed to 5 years in the previous draft. Makes sense I guess, especially as these substances should not leak out in the first place. Please share any detail with this column if you have experience to the contrary.
Other examples include laptop PC's at 8 years, while a digital camera, LCD monitor and desktop PC are all specified as 10 years.

There are still several possibilities for determining the EFUP. Two methods currently popular with manufacturers are:
1. A figure from the annex, as above, if the product is either the same or similar to the examples listed, made in a similar way using comparable materials
2. Based on the "technical life". In reality, this is the longest time (not the average) that a product will take from the date of production until the date it is recycled. This will include time after production and before being put into service as well as time after refurbishment or repairs.

No doubt further draft standards will be published on this subject over time just to keep manufacturers on their toes!!
No-one wants to quote an EFUP that is too optimistic and face the wrath of the authorities, likewise quote an EFUP that is shorter than your competitors and face losing market share!

As always, please contact me with any points regarding China RoHS or legislation, in general, that impacts our industry.

Directive Decoder

One topic that was the subject of much debate was the decision of UK enforcement authority NWML to consider Semiconductor Evaluation Boards as within the scope of EU RoHS. Their website states:
The term "Evaluation Boards" covers a broad range of products from those that are fairly simple through to fully integrated complex systems. In most cases an evaluation board is effectively a single board computer allowing connection of peripherals and / or input devices to facilitate the programming and testing of chips. Therefore, most evaluation boards are included under Category 3 -IT Equipment- of the WEEE Directive and must comply with RoHS.
Fair enough although it did catch some manufacturers out.

So what about electronic kits for self assembly?
I was having a chat about this with my good friend, and global RoHS expert, Paul Goodman at ERA Technology.
He felt that it depended on the function of the parts and who does the assembly.
Thinking this through, if assembly is carried out by anyone other than the user, then the status will depend on the function of the assembled product. Clearly, if parts are sold to the user, each part needs to be assessed, not the assembled product. This is because the EU RoHS Directive applies to "finished products" that are "Put Onto The Market". POTM is defined by the "Blue Guide" which says that a product has NOT been POTM if further assembly work is required.

Drop me a line if your business is involved with either semicondutor evaluation boards or electronic kits for self assembly.

Directive Decoder

In a couple of months time the media will be full of "RoHS A Year On" features.
Thought I would get in first, well, it is nearly April after all!!
During the coming weeks I will share the significant developments, or lack of, with you.
Most EU member states are only just beginning to carry out market surveillance, although NWML has been carrying out enforcement activities for some time. They claim that 95% of products are not 100% RoHS compliant. Most have just a few components which donot comply with rework using tin/lead solder a common cause of non-compliance.
Scope within the EU is still unclear with differing opinions on offer. For example, Holland
assumes that car radio's, if bought by consumers, will be within the scope of RoHS, not ELV, unlike the UK and most other Member States. Fixed installations are another area of disagreement. Cable is still unclear also, with NWML suggesting that they might be household appliances based on the dictionary definition of "appliance" which could be almost anything whereas "household appliance" implies a much narrower range of products.
I understand that the DTI still disagree's with the European Commission on cables, so watch this space.

What's your experience of the first nine months or so, please drop me a line.

Directive Decoder

If you will allow me, just a quick plug for NEPCON which this year falls between May 15th and 17th at Birmingham NEC.
Electronics Yorkshire has arranged a series of seminars each day and have invited me to ramble on about China RoHS at 2PM Tuesday, Wednesday and Thursday.
Electronics Yorkshire support and assist the growth of the electronics sector throughout Yorkshire and the Humber by:
+ Providing an industry dedicated training centre
+ Making some of the very latest, leading edge equipment available for use / training etc
+ Operating a membership network for electronics businesses
Why not have a look at their excellent web-site and see
what they can do for you: http://www.electronicsyorkshire.org.uk
They will also host a seminar around design for manufacture with IPC standards featuring specialists Peter Burnley and Eric Hinsley.

Mark Shayler and Leigh Holloway, from environmental consultancy specialists eco3, will also offer words of wisdom on the RoHS, WEEE, REACH, EuP and Battery Directives throughout the day.
These guys are vastly experienced in eco design and are experts in understanding the business implications of legislation and can assist in formulating effective strategies: http://www.ecothree.com/

I look forward to seeing you there.

Directive Decoder