I raised this issue with an EU knowledgeable attorney last year. The
clause Dan quotes was put into the directive specifically so that
RoHS would not be an indirect ban on NiCad batteries. Any issues
dealing with batteries are left exclusively to the battery directive.
I was told, in part ....
"This issue was brought to the attention of DG Environment and the EC
early in the development of the WEEE and RoHS Directives, because of
their apparent impact on the existing Battery Directive. ...... In
response to complaints that the RoHS Directive was a back-door means
of banning consumer and industrial Ni-Cds, DG Environment agreed to
provide that the WEEE and RoHS Directives would not preempt the
existing or proposed Directives on batteries or other specific
Directives on hazardous waste management. The result was the
inclusion in the WEEE and RoHS Directives of the language [quoted].
While the wording is not as specific as one might prefer, DG
Environment has assured interested parties that the effect is to
carve out the present and proposed regime for Ni-Cd batteries. Thus
the WEEE and RoHS Directives do not by their own terms ban Ni-Cd
batteries ...
Charles F. Dolci
Director - Environment, Health & Safety
Sun Microsystems, Inc.
*MIME-Version: 1.0
*From: "Kallin, Dan" <[log in to unmask]>
*Subject: [LF] RoHS Question re Nicads
*X-To: "Leadfree Electronics Assembly E-Mail Forum."
<[log in to unmask]>
*To: [log in to unmask]
*
*Greetings,
*This is a little off topic, but there seems to be some good
expertise on EU
*Legislation in the group and it probably effects others.
*
*A question has arisen how the RoHS will affect batteries,
specifically
*Nickel Cadmium (NiCad).
*Are these included in the ban and if so how?
*Only if they are a part of apiece of electrical equipment?
*
*From the RoHS directive:
*(9) This Directive should apply without prejudice to Community
legislation
*on safety and health
*requirements and specific Community waste management legislation, in
*particular
*Council Directive 91/157/EEC of 18 March 1991 on batteries and
accumulators
*containing
*certain dangerous substances *
**OJ L 78, 26.3.1991, p. 38. Directive as amended by Commission
Directive
*98/101/EC
*(OJ L 1, 5.1.1999, p. 1).
*
*I have read the battery directive and seen no bans on Nicads.
*
*Any Thoughts?
*__________________________________________
*Dan Kallin Environmental & Safety Engineer
* Bose Corporation Framingham, MA 01701
* [log in to unmask]
* 508-766-7136 (phone)
* 508-766-7086 (fax)
*__________________________________________
*
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