Vern,
Good luck finding it in the directive. I have long felt the onerous
requirements imposed by the Automotive industry on their suppliers is
based on a strict and literal reading of Article 8 paragraph 3.
The referenced directive, 67/548/EEC, (after nearly 40 years) does not
leave much out of the definition of a hazardous substance
http://europa.eu.int/comm/environment/dansub/home_en.htm
--------------------------
From the ELV directive:
11. "hazardous substance" means any substance which is considered to be
dangerous under Directive 67/548/EEC;
Article 4
Prevention
1. In order to promote the prevention of waste Member States shall
encourage, in particular:
(a) vehicle manufacturers, in liaison with material and equipment
manufacturers, to limit the use of hazardous substances in vehicles and
to reduce them as far as possible from the conception of the vehicle
onwards, so as in particular to prevent their release into the
environment, make recycling easier, and avoid the need to dispose of
hazardous waste;
Article 8
Coding standards/dismantling information
..
3. Member States shall take the necessary measures to ensure that
producers provide dismantling information for each type of new vehicle
put on the market within six months after the vehicle is put on the
market. This information shall identify, as far as it is needed by
treatment facilities in order to comply with the provisions of this
Directive, the different vehicle components and materials,
and the location of all hazardous substances in the vehicles, ....
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^.
(Emphases added)
------------------------------------------
There is similar language and requirement in the WEEE directive, WITH AN
EXPANDED DEFINITION OF WHAT SHOULD BE REPORTED! but I have not yet heard
of many companies asking for the level of detail the Automotive industry
looks for except those who supply both industries.
There was however also significant effort, primarily from Japan if my
memory serves me, to include 100% declaration in the Joint Industry
Guide.
------------------------------------------
From the WEEE directive
(l) "dangerous substance or preparation" means any substance or
preparation which has to be considered dangerous under Council Directive
67/548/EEC or Directive 1999/45/EC of the European Parliament and of the
Council.
Article 11
Information for treatment facilities
1. In order to facilitate the reuse and the correct and environmentally
sound treatment of WEEE, including maintenance, upgrade, refurbishment
and recycling, Member States shall take the necessary measures to ensure
that producers provide reuse and treatment information for each type of
new EEE put on the market within one year after the equipment is put on
the market. This information shall identify, as far as it is needed by
reuse centres, treatment and recycling facilities in order to comply
with the provisions of this Directive, the different EEE components and
materials, as well as the
location of dangerous substances and preparations in EEE.
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
Dan Kallin
Program Director
EH&S Management, Consulting and Compliance
Earth Tech, Inc.
196 Baker Avenue
Concord, Massachusetts 01742-2167
Phone: 978.371.4155 Fax: 978.371.2468
Mobile: 978.760.0779
[log in to unmask]
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Weik, Vern
Sent: Tuesday, November 29, 2005 11:53 AM
To: [log in to unmask]
Subject: [LF] FW: End-of- life Vehicles vs RoHs reporting
Hi all EU directive experts.
I would like to start by saying, I have been reading these e-mail for a
long time and have gathered great knowledge. Thank you.
I have mainly been involved with reporting to EU RoHs directive, but
recently I have been asked to use an End-of-life Vehicles reporting
software to gather the information from my suppliers. This software
seems to be an over kill. Can anyone highlight the main difference
between the two, or give me a link to the End-of-Life Vehicles
directive?
Thanks in Advance
Vern T Weik
CONFIDENTIALITY NOTICE: This message (including any attachments) may
contain Molex confidential information, protected by law. If this
message is confidential, forwarding it to individuals, other than those
with a need to know, without the permission of the sender, is
prohibited.
This message is also intended for a specific individual. If you are not
the intended recipient, you should delete this message and are hereby
notified that any disclosure, copying, or distribution of this message
or taking of any action based upon it, is strictly prohibited.
Chinese Japanese
www.molex.com/confidentiality.html
------------------------------------------------------------------------
-------Leadfee Mail List provided as a service by IPC using LISTSERV
1.8d
To unsubscribe, send a message to [log in to unmask] with following text
in
the BODY (NOT the subject field): SIGNOFF Leadfree
To temporarily stop/(start) delivery of Leadree for vacation breaks
send: SET Leadfree NOMAIL/(MAIL)
Search previous postings at: http://listserv.ipc.org/archives
Please visit IPC web site
http://www.ipc.org/contentpage.asp?Pageid=4.3.16 for additional
information, or contact Keach Sasamori at [log in to unmask] or 847-615-7100
ext.2815
------------------------------------------------------------------------
-------
-------------------------------------------------------------------------------Leadfee Mail List provided as a service by IPC using LISTSERV 1.8d
To unsubscribe, send a message to [log in to unmask] with following text in
the BODY (NOT the subject field): SIGNOFF Leadfree
To temporarily stop/(start) delivery of Leadree for vacation breaks send: SET Leadfree NOMAIL/(MAIL)
Search previous postings at: http://listserv.ipc.org/archives
Please visit IPC web site http://www.ipc.org/contentpage.asp?Pageid=4.3.16 for additional information, or contact Keach Sasamori at [log in to unmask] or 847-615-7100 ext.2815
-------------------------------------------------------------------------------
-------------------------------------------------------------------------------Leadfee Mail List provided as a service by IPC using LISTSERV 1.8d
To unsubscribe, send a message to [log in to unmask] with following text in
the BODY (NOT the subject field): SIGNOFF Leadfree
To temporarily stop/(start) delivery of Leadree for vacation breaks send: SET Leadfree NOMAIL/(MAIL)
Search previous postings at: http://listserv.ipc.org/archives
Please visit IPC web site http://www.ipc.org/contentpage.asp?Pageid=4.3.16 for additional information, or contact Keach Sasamori at [log in to unmask] or 847-615-7100 ext.2815
-------------------------------------------------------------------------------
|
