Bob, the only thing I would add is that the information below is from Gary Nevison of Newark/Farnell, as a column or a commentary. I have been nervous of Newark/Farnell since 2006 since they were the first I knew of to propose a US style RoHS to keep states from enacting their own patchwork of regulations. (that has now happened with NEMA pushing for HR 2420 introduction in the US House.
I am not disagreeing, just waiting for other interpretations. Other recent EU notes have said maybe the EU parliatment elections made that body a bit more conservative leaning. Bad news - the green party elected to the EU parliament is concentrating on running environemntal matters. Then again, there is the EU Commission noted here - and can someone on this forum explain how the Commission is appointed and who they report to, if not the EU Parliament
Denny Fritz
Gary Nevison, director of legislation and environmental affairs at Newark and Farnell, contributes his views on the electronics supply chain and environmental compliance's most critical topics -- ROHS (all variations around the world), REACH, EUP, WEEE directives, and on whatever else comes up in this ever evolving business channel.
-----Original Message-----
From: Bob Landman <[log in to unmask]>
To: [log in to unmask]
Sent: Thu, Sep 17, 2009 4:53 pm
Subject: [LF] New ROHS proposals seek to change scope to encompass all electrical and electronic equipment unless specifically excluded
New ROHS proposals20seek to change scope
ep 17 2009 8:50AM | Permalink |Comments (0) |
Following discussions between EU Member States and the Council of Ministers, new
roposals have been put forward by Sweden, which currently owns the EU
residency, to amend the scope of the ROHS (Restriction of Hazardous Substances)
irective.
nder the proposals the scope will change to encompass all electrical and
lectronic equipment unless specifically excluded. Currently there are eight
roduct categories with binding examples of what products fall within scope. A
ecast, published in December 2008, also proposed the phased in addition of
ategories 8 and 9 (medical devices and monitoring and control instruments).
nder the new proposals all electrical and electronic equipment (EEE) will fall
ithin scope, unless specifically excluded. Annex I (the 10 broad product
ategories) and Annex II (binding list of product examples) have been deleted
rom the text of the ROHS recast and will now sit, as before, within the WEEE
Waste Electrical and-Electronic Equipment) directive, although Annex II is
eferred to as indicative as opposed to a binding list.
here are new exclusions from the ROHS text such as large-scale stationary
ndustrial tools (LSIT), but the impact of the revised proposals is clearly to
nclude products that are not currently in scope.
t is also proposed to delete Annex III that lists four substances - BBP, DBP,
EHP, and HBCDD for priority assessment, leading to possible restrictions.
owever, the Commission intends to adopt a20methodology for the review of the
estricted substances in Annex IV (the original six possible, but unlikely) and
ew substances where deemed necessary in the future, based on the process set
ut in Articles 69 to 72 of the REACH (Registration, Evaluation and
uthorization of Chemicals) regulations.
his would look to review a substance used in EEE, or the waste derived from it,
hat poses a hazard to human health or the environment that is not adequately
ontrolled.
owever, industry will be interested in the scope, where any product that relies
n electricity to function could be included, as well as the status of some of
he grey area products. No longer will there be the “is it in scope or is it
ut” issues as with, for example, semiconductor development tools at present, as
verything will be within scope unless specifically excluded.
OHS was previously unclear, especially for fixed installations, and it is
robable that these proposals are an attempt to resolve this. However,
equipment that is part of equipment that is out of scope is itself out of
cope” remains in the text so uncertainty is likely to continue.
Bob Landman
&L Instruments, LLC
www.hlinstruments.com/
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