Directive Decoder

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).

The RoHS Recast Directive 2011/65/EU contains new CE mark obligations and a standard format, in Annex 6, for a new Declaration of Conformity for "finished goods".

Looking at my mail box the CE mark obligations are already causing industry some concern.

In the UK, NMO is aware and are hoping to publish guidance later in the year but this is not straight forward, especially when you open it up to the wider CE picture.

Definitely one to watch this space.

RoHS CE Mark

Directive Decoder

The RoHS Recast Directive 2011/65/EU includes new obligations around CE marking.

In a nutshell a Declaration-of-Conformity (DoC) is required for products in scope. Generally that would refer to finished equipment and the format of the DoC is outlined in Annex 6 of the Directive.

Components, as per the original RoHS directive, are not in scope but clearly need to be compliant when used in finished goods.

Industry should continue to collect a certificate-of-compliance covering components as before.

Unless you have been on holiday on another planet no doubt you will be aware of the popular debate on whether or not an open PCB, with no case, can be considered finished equipment.

Product can be considered finished if it is sold to end-users who use it as a complete and finished product. The lack of an enclosure does not mean it isn't finished.

Most EU Member State authorities regard plug-in PCBs for PCs as finished products.

Directive Decoder