Directive Decoder

Dear all

First of all, a very Happy New Year to all the readers of this blog.

I thought I would start 2009 with a brief summary of two regulations in the news:

Regulation 765/2008/EC specifies the rules for conformity assessment bodies that test and assess equipment for compliance with such as EMC, LVD and RoHS in the future. It also sets a framework for market surveillance and provides the framework for CE marking and control of imports.

Regulation 768/2008/EC defines what manufacturers, importers and distributors need to do to demonstrate compliance with CE mark directives such as EMC, LVD and RoHS in the future. It describes conformity assessment procedures such as what should be included in technical files and declarations of conformity.

Suspect we will hear more about these with the potential impact on the RoHS Directive.

Directive Decode

As the second part of the RoHS review on scope Oko Institute has looked at the exemptions. Here, expert Dr. Paul Goodman of ERA Technology, best guesses what might well happen when the changes are announced a little later in the year.

Click here for a table covering all of the exemptions.

Directive Decoder

The Waste Electrical and Electronic Equipment (WEEE) Directive has faced technical, legal and administrative difficulties since it came into force in 2003.

Following a comprehensive review the European Commission has put forward several proposed amendments to ease the burden on Producers without lowering the level of environmental protection.

Revised WEEE Directive

Directive Decoder

The UK Government has published two stakeholder consultations into the implementation of the WEEE Directive and New Battery Directive.

This is an opportunity for industry to have its say:

WEEE Consultation

Battery Consultation

Directive Decoder

Towards the end of 2008 we witnessed a significant increase in legislative activity.

The New Battery Directive came into force in September, the first Substances of Very High Concern were published by the European Chemicals Agency in October and, at the beginning of December, there were announcements from Brussels around proposed changes to the RoHS and WEEE Directives.

So, what can we expect during 2009?

The European Chemicals Agency (ECHA) has launched a public consultation on the first draft recommendations around substances to be included in the list of substances subject to authorisation. As RoHS and REACH processes start to come together you will note that the 4 proposed substances for priority assessment, recently announced under "RoHS2" are included in the list....BBP, DBP, DEHP and HBCDD.

ECHA announcement

Directive Decoder

It might just be me, but there feels to be more going on at the minute in the world of legislation than at any time since the pre RoHS days.

So I thought I would provide some brief updates.

Click on the link to find out more about:

The 4 potential restricted substances proposed under "RoHS2"

Category 8 (medical devices) and 9 (monitoring & control instruments) products in scope and those requiring clarity

Timescales for "RoHS2" implementation, restricted substances and exemptions

REACH substances for authorisation

Have a quick look at these articles and bring yourself up-to-date on the latest legislative developments.

Directive Decoder

What tonnage of batteries do you import?

That includes batteries despatched from outside the EU into non UK "pods".

If more than 3 tonnes then you could be classified as a "Large Producer" and face unexpected costs.

If this concerns you, then have your say and reply to the UK consultation paper.

Directive Decoder

REACH (Registration, Evaluation, Authorisation - and restriction - of CHemicals) is a regulation which many companies in the European Union will have to comply with.

REACH was introduced because many thousands of chemicals are used in the EU without the risks to human health and the environment being fully understood. The attached guide has been brought up-to-date to include the recent announcements around Substances of Very High Concern and gives guidance on how manufacturers and importers need to comply as well as the impact on downstream users.

REACH Guide

Directive Decoder

The European Commission (EC) has published its proposals to amend the directive 2002/95/EC (RoHS) and this introduces new obligations for the electronics industry. The main changes that are being proposed in "RoHS2" will affect most of the electronics industry and these include:

-         Originally, compliance was the responsibility of  "producers" who had to ensure that they supplied compliant equipment. The original directive defined "Producer" but interpretation of who is responsible has not always been straightforward. The EC's proposals remove all references to producers and introduce four new Articles that clearly define the responsibilities of manufacturers (Article 7), authorised representatives (Article 8), importers (Article 9) and distributors (Article 10).

-         Medical Devices (category 8) and Monitoring and Control Instruments (Category 9) will be included in the scope of RoHS from 1 January 2014 except for in vitro diagnostic (IVD) from 1 January 2016 and industrial monitoring and control instruments from 1 January 2017. Implanted medical devices will be reviewed before 2020 do determine if these will be included.

The European Commission (EC) has published draft proposals for a regulation covering ac induction motors and drives.

Key elements of the proposals are as follows: