Directive Decoder

Once there was only the RoHS Directive in the European Union that we had to think about.
Today there are 10 pieces of legislation upon us, or in the pipeline, that will impact our industry.
As well as the current review on the scope of EU RoHS, which could lead to more products (likely) and substances (possibly) included, we now have:

Energy using Products (EuP)
REACH Policy Reform
WEEE
China RoHS
South Korean RoHS
Australian RoHS
Norwegian PoHS
Batteries
ATEX

As well as an ever increasing number of substance restrictions in North America

Let me know which of these has the biggest impact on your company, and why, and I will share in this column.

Directive Decoder

It crossed my mind that test equipment is becoming a hot topic. Monitoring and Control Instruments are category 9 of the WEEE Directive and therefore do not fall within the scope of EU RoHS today.

However, with the review on scope of EU RoHS currently taking place and with proposed legislation in Norway and China all that could change.

So what does REACH actually mean?

Here we breakdown Registration, Evaluation, Authorisation (and restriction) of CHemicals:

Registration - Chemical producers are obliged to register safety data for all chemicals produced in quantities above one tonne a year to a central agency. Less information is required the lower the tonnage of chemicals produced per year, with only very basic information required for 1-10 tonnes.

How is the RoHS review on definitions, and the clarity thereof, likely to affect the product scope on RoHS?

Talking to expert Paul Goodman of ERA he feels:

Fixed Installation – this is likely to be rejected as criteria for exclusion for exclusion from WEEE and so any equipment installed in buildings (fire alarms, CCTV, electric heaters, boiler controls, air-conditioning equipment etc) will be clearly in scope of WEEE.
Put-On-The-Market is unlikely to affect scope.

Spare Parts – may include or exclude finished products that are used as spare parts and it’s difficult to see which way they will go. The EMC directive definition maybe adopted which states that any item used to repair a product is a spare part. Therefore, for example, if a replacement keyboard is needed for a PC, this is unlikely to be regarded as a spare part.

Directive Decoder

Once there was only the RoHS Directive in the European Union (EU) causing problems for the design engineer community.

Today several other pieces of legislation provide challenges to industry and often impact on the design phase of a product.

Many of these directives are driven from Europe but the world now seems to be a smaller place when it comes to tackling environmental issues with China, Korea, Australia, North America and, to a lesser extent, India all considering their own approach to restricting hazardous substances as well as more efficient ways of recycling.

I understand hopes of a China RoHS "Priority Products Catalogue" in 2007 have virtually disappeared.

It is not yet certain which of the many "ministries" are to be tasked with putting the catalogue together.