Directive Decoder

Was talking to Dr. Paul Goodman at ERA Technology about the RoHS review, and when we can expect any announcements.

"Oko's additional substances report was written for the European Commission and so it is the Commission that will publish it on their website, when they are ready. This may be within the next month or so. The Oko report is just one of the reports and submissions that the EC has to consider for their proposals to amend RoHS. It is a bit late to influence the EC now but after their proposals are published, these will be discussed by the European Parliament and Council in co-decision and they will eventually amend the RoHS directive. It will be difficult but not impossible to influence the politicians and some trade associations and manufacturers will be lobbying for their views to be considered. Of course so will Greenpeace etc".

Dr Goodman is also a judge of this year's Live Edge competition at Premier Farnell.

 

Directive Decoder

I recently received a standard letter from a very large company who appear, on the face of it, to have an incorrect interpretation of the New Battery Directive.

They believed that all batteries on the market that did not comply with the New Directive would have to be withdrawn after its implementation date of 26/9/08.

This is not the case.

All batteries put on the market before 26/9/08 should comply with the "current" Battery Directive (91/157/EEC). Any put on the market on, or after, 26/9/08 need to comply with the numerous requirements of the New Battery Directive (2006/66/EC).

No recall or withdrawal is required.

 

 

Directive Decoder

The European Commission has delayed the publication of draft regulations reviewing the WEEE and RoHS Directives. Originally planned for September 2008 the guidance will not now be published until November or December.

The WEEE review is expected to contain proposed measures to harmonise national WEEE registration and clarify legal responsibilities.

The RoHS review is likely to propose new substance restrictions and an extension to the scope of products covered by the directive.

The REACH (Registration, Evaluation, Authorisation - and restriction of Chemicals) Regulations define an "article" as "an object which during production is given a special shape, surface or design which defines its function to a greater degree than does its chemical composition".

A widely used example would be a polystyrene cup, which is an article because its shape is more important than its composition, which is pure polystyrene. The difference is important in the terms of REACH because only chemicals need to be registered and, where required, authorised. The obligations for substances in articles are different and in general less onerous.