Directive Decoder

On 1 September the European Chemicals Agency published details of a consultation around the 2nd batch of candidate SVHCs.

As with the first batch there are 15 proposed.

However, not all are expected to be used in electrical and electronic equipment. Here chemist Dr Paul Goodman of ERA Technology, trading as Cobham Technical Services gives his view:

The Environment Agency is getting some stick from certain manufacturers for not getting the message across regarding the UK battery regulations.

Seems a little unfair to me and twice they have asked me to help raise awareness. I am more than happy to link to their flyer again.

Environment Agency awareness leaflet

In the meantime, eight potential battery compliance schemes are seeking approval. The succesful BCS are due to be announced at the end of September.

Potential Battery Compliance Schemes

Producers then have until October 15th to register with one of these.

Lots of positioning is going on, believe me!!

Directive Decoder

The European Union (EU) WEEE Directive (2002/96/EC) was adopted in 2003 and came into force on 13 August 2005 although most EU States were late. However, by 1 January 2008 all EU States had implemented national WEEE legislation. Unfortunately for manufacturers, there are many significant differences between Member States and requirements vary considerably. The WEEE Directive appears to be straightforward having only 19 Articles whereas the much longer EU REACH regulation has 141 Articles. However, implementation of WEEE is very complex because of the different approaches that have been adopted by EU Member States.

There are many reasons why engineers would want to design new energy efficient electrical products. One is concerns over global warming as this is resulting in legislation worldwide that requires more energy efficient designs. The European Union (EU) has adopted the Ecodesign of Energy using Products (EuP) directive but USA, Australia and many other countries also have legislation covering a variety of products.

The European Chemicals Agency has announced details of a consultation around the next proposed batch of Substances of Very High Concern.

These will have a significant impact as they are expexted to come in to force early next year which, the way things are going, could well be before many manufacturers have provided the obligatory REACH SVHC data on the first batch of 15.

If you have forgotten all about China RoHS then do not forget your potential obligations.

Here is my latest update that may help your planning.

China RoHS update

Directive Decoder

If you are still getting to grips with REACH, what it is, and how it impacts your business then I have updated my two guides which may help:

REACH Step-by-Step Guide

REACH Substances in Articles

Hope they help.

Directive Decoder

The EU RoHS Enforcement Authorities are due to meet on Thursday.

One of the topics will be the on-going issue around semiconductor development tools and compliance and their scope status.

Always seemed pretty clear in the UK but clearly not all Member States.

Watch this space!

Directive Decoder

Following discussions between EU Member States and the Council of Ministers new proposals have been put forward by Sweden, who currently owns the EU presidency, to amend the scope of the RoHS Directive.

Under the proposals the scope will change to encompass all electrical and electronic equipment unless specifically excluded. Currently there are 8 product categories with binding examples of what products fall within scope. A recast, published in December 2008, also proposed the phased in addition of categories 8 and 9 (medical devices and monitoring and control instruments).

The WEEE directive requires 10 categories of electrical equipment to be collected, treated, recycled and disposed of when it reaches end of life. The directive sets targets for the percentages of materials that must be recovered and includes a list (in Annex II) of parts that have to be removed and then recycled separately. The Directive also includes a requirement that manufacturers design equipment so that they can easily be recycled although this has not yet been translated into national legislation in any EU State.

Recycling is a cost that can be significant and is paid for by the producer (usually the manufacturer or importer). In effect it is a sales cost, as it must be financed when the product is sold. The cost of recycling can be influenced by the design of the equipment although whether the manufacturer can realise these benefits depends on whether they collect and recycle their own equipment at end of life (by which they can) or if it is collected and recycled by compliance schemes that collect a wide range of products from many producers (where the benefits are more limited).

Those of you who have followed my articles on Dimethyl Fumarate (DMF), the anti-mould substance found in leather sofa's and armchairs might be interested to know that a court case was due to open today (22 September).

The case is to determine how much compensation should be paid out to the victims of sofa burns.

People across the UK developed skin complaints as a result of sitting on leather settees imported from China.

Are you looking for a recycler / disposal company to help you and your business, but don't know where to turn?

Research consulting company Oakdene Hollins, experts in economic waste management, re-manufacturing and re-use has put together the attached list of companies that offer a wide range of services and expertise:

Oakdene Hollins recommended list

If you require an accredited service in North America then try the recently formed e-stewards

Directive Decoder

Many of you will be aware of the on-going debate around the RoHS status of Semiconductor Evaluation Boards often referred to as Development Kit.

Are they in, or out of scope and, if in, which category?

The RoHS Enforcement Authorities met on 17 September and these products were on the agenda.

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FACEBOOK (Legislation Eye)

TWITTER (GaryNevison)

LINKEDIN (My Legislation Services Group)

If there is anywhere else that you would like to read my posts then drop me a line.

Please sign up to "follow" me or become a "fan" and join the legislative community.

Directive Decoder

I have my first ERG meeting this Wednesday at the BIS Conference Centre in London.

The ERG was set up as a result of one of the recommendations from the Electronics Innovation Growth Team report in 2005. It was recommended that the then DTI should set up a cross Government / Industry group to ensure that the legitimate interests of the sector were taken into account in the development of relevant regulation. In response, DTI set up the "Electronics Regulatory Group" (ERG) which now meets on a quarterly basis.

On 5 May 2009, new regulations came into force about the way batteries (including re-chargeable) are collected, treated and recycled in the UK. The Batteries Directive will improve the environmental performance of batteries and those involved in their life cycle.

The regulations aim to move the UK from its 2007 rate of recycling 3% of portable batteries to 25% (approximately 7500 tonnes) by 2012, rising to at least 45% in 2016.

Anyone who places portable batteries, or products containing them, onto the UK market for the first time will be classified as a Producer and, if they place more than 1 tonne onto the market, will need to join a Battery Compliance Scheme (BCS) by 15 October that will arrange for collection, treatment and recycling of waste batteries on their behalf.

For further information, the Environment Agency has issued some simple guidance click here

Directive Decoder