The 1994 packaging directive has recently been revised - I think around January this year.
Kay
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-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Kallin, Dan
Sent: 26 October 2004 17:40
To: [log in to unmask]
Subject: Re: [LF] RoHS Applicability Question
Hi Pascal,
The question was on RoHS applicability.
RoHS scope refers to 'electrical and electronic equipment', not WEEE.
2002/95/EC
Article 2
Scope
1. Without prejudice to Article 6, this Directive shall apply to electrical
and electronic equipment falling under the categories 1, 2, 3, 4, 5, 6, 7
and 10 set out in Annex IA to Directive No 2002/96/EC (WEEE) and to electric
light bulbs, and luminaires in households.
Article 3
Definitions
For the purposes of this Directive, the following definitions shall apply:
(a) "electrical and electronic equipment" or "EEE" means equipment which is
dependent on electric currents or electromagnetic fields in order to work
properly and equipment for the generation, transfer and measurement of such
currents and fields falling under the categories set out in Annex IA to
Directive 2002/96/EC (WEEE) and designed for use with a voltage rating not
exceeding 1000 volts for alternating current and 1500 volts for direct
current;
Consumables are covered in WEEE.
The examples of consumables I have seen are printer cartridges, i.e. they
are consumed in using the product.
I can also see that labels etc which are part of the product would be
covered as WEEE.
I thought I had seen something which brought Instructions manuals into
packaging, but cannot refind it. So I am a not sure if/how the CD and
manual are regulated.
Regarding heavy metals in packaging:
EUROPEAN PARLIAMENT AND COUNCIL DIRECTIVE 94/62/EC of 20 December 1994 on
packaging and packaging waste
THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION,
Article 11
Concentration levels of heavy metals present in packaging 1. Member States
shall ensure that the sum of concentration levels of lead, cadmium, mercury
and hexavalent chromium present in packaging or packaging components shall
not exceed the following:
- 600 ppm by weight two years after the date referred to in Article 22 (i);
- 250 ppm by weight three years after the date referred to in Article 22
(i);
- 100 ppm by weight five years after the date referred to in Article 22 (i).
Dan
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]]On Behalf Of Pascal Guiheneuf
Sent: Monday, October 25, 2004 10:25 AM
To: [log in to unmask]
Subject: Re: [LF] RoHS Applicability Question
Dan,
Maybe some nuance here by the WEEE definition itself :
'waste electrical and electronic equipment' or 'WEEE' means electrical or
electronic equipment which is waste within the meaning of Article 1(a) of
Directive 75/442/EEC, including all components, subassemblies and
consumables which are part of the product at the time of discarding;
Regards
Pascal Guihéneuf
Nortel Networks Wireless
ESN 754-2704 or 33.6.64.04.27.04 (mobile)
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]]
Sent: lundi 25 octobre 2004 14:57
To: [log in to unmask]
Subject: Re: [LF] RoHS Applicability Question
The manual and packaging are not electronic products, I do not see how they
could be covered by WEEE or RoHS. I believe they are already covered by the
packaging directive anyway.
__________________________________________
Dan Kallin Environmental & Safety Engineer
Bose Corporation Framingham, MA 01701
[log in to unmask]
508-766-7136 (phone)
508-766-7086 (fax)
__________________________________________
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]]On Behalf Of Jon Sirota
Sent: Saturday, October 23, 2004 1:58 PM
To: [log in to unmask]
Subject: [LF] RoHS Applicability Question
Our company sells electronic assemblies which plug into servers and desktop
computers. It would appear that, except for possible SERVER exemptions,
these assemblies will have to be RoHS compliant in order to sell into the EU
after the start date.
I have assumed that all of the collateral materials which also go along with
the above assemblies also has to be RoHS compliant - such as the manual, the
packing materials, the labels on the enclosed CD, the CD itself, the outer
packaging, the sealing tape, etc.
Does anyone on the list have a sense of the applicability of RoHS to these
materials which are shipped at the same time as the electronics,and which
are part of the product that the customer buys and receives?
Thanks for your thoughts.
Jon Sirota
Brooktrout, Inc.
[log in to unmask]
Brooktrout, Inc.
250 First Ave
Needham, MA 02494
Tel: +1 (781) 433-9474/Fax: +1 (781) 433-9274
www.brooktrout.com
Your Hook into the New Network
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