Directive Decoder

Allowing for an 18 month transposition period the recast of the Waste Electrical and Electronic Equipment Directive could become UK law by the end of 2012 although there is a possibility that it may drift into 2013.

A draft report was published in February. Orgalime, the European Federation of major trade associations has responded and the reply includes input from such as GAMBICA. The latter has proposed amendments to limit liabilities on Producers of Medical Devices (category 8) and Monitoring and Control Instruments (category 9).

Key issues include the widening of scope to encompass all EEE although exemptions will apply. As a result Producers would be liable for a wider range of equipment than at present and this would draw in a new range of companies who are currently exempt.

There are concerns within industry over a European Parliament proposal to increase the scope of the RoHS Directive to capture all electrical and electronic equipment rather than just the current eight (plus two more in 2014) product categories.

Orgalime, the European Engineering Industries Association representing the interests of, among others, the Electrical and Electronic industries feels that the proposal has not been properly thought through and has called for a thorough impact assessment.

The substantial changes proposed would bring nearly all equipment including trains, planes, power plants and elevators within the scope of RoHS even though they have specific safety requirements and are treated differently at the end of their life.

The benefits of restricting further hazardous chemicals under the RoHS Directive has been questioned in an impact assessment published by the European Parliament.

For example the report suggests that the costs of banning the phthalates DEHP, BBP and DBP, used as plasticisers in PVC "far outweigh the benefits" to human health and also adds that the environmental benefits are also unlikely to justify the costs.

It is looking likely that RoHS will become a "CE Mark Directive" over the next couple of years. This could have a massive, resource sapping, impact on manufacturers, importers and distributors, regardless of size.

Here we look at, in particular, how it will impact the manufacturer.

As a caveat to the following where optoelectronic and display modules are used as types of components and are sold to be used as components in other products, it is not yet clear what action will be needed as this is not yet defined. As they are not finished products it is possible that the may not need to be CE marked.

The European Commission's (EC) proposals will make RoHS a CE mark Directive and so any products in scope of RoHS must be CE marked to demonstrate that they comply. Most displays such as TV's and monitors are already CE marked to show that they comply with both the EMC and Low Voltage Directives (LVD).

Legislation to improve chemical safety has been put before both houses of Congress.

The proposed Safe Chemicals Act 2010 will shift the burden of proving safety onto manufacturers and users while empowering the US Environmental Protection Agency (EPA).

Simultaneously a similar draft called the Toxic Substance Control Act 2010 was published for discussion.

Those of you who follow my blogs will know that I have posted a few articles on the subject of the chemical DMF (dimethyl fumarate) which has been used in the production of several models of sofa.

Customers who were left with a horror rash and peeling skin, with many of them fearing skin cancer, are in line to receive compensation of over £20m in total.

The High Court in London approved a prompt settlement between the victims and insurers of the shops that sold the Chinese made furniture which left many customers complaining of burns.