Sadly no, that would have provided some direction and consistency for
interpretation.
I mean the legal basis for RoHS is Article 95 of the EC Treaty, single
market
http://www.dti.gov.uk/sustainability/weee/ROHSEM.pdf
and the legal basis for WEEE is Article 175 of the EC treaty.
http://www.dti.gov.uk/sustainability/weee/WEEEEM.pdf
It is this difference that allows only one set of chemicals to be
restricted across the EU, but allows dozens of producer registries.
My understanding is that If WEEE had been passed under Article 95, there
would be a sinngle EU wide producer registry.
In answering your question, I answered mine. It appears EUP was passed
under article 95.
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: Nic Bowker [mailto:[log in to unmask]]
Sent: Wednesday, March 01, 2006 10:27 AM
To: (Leadfree Electronics Assembly Forum); Kallin, Dan
Subject: RE: [LF] Don't be left out on the Next RoHS
Dan,
Are you saying that RoHS is under the "New Approach"? My understanding
is that it wasn't - see page 4 of the following document -
http://www.dti.gov.uk/sustainability/weee/ROHS_Compliance_Executive_Summ
ary.pdf
under the "self declaration" bit
If it is new approach that makes it interesting with regard to enforcers
understandings of exemptions.
Nic Bowker
Technical Resources Adviser
PLASA Ltd.
38 St Leonards Road, Eastbourne, East Sussex, BN21 3UT, UK.
Tel: +44 (0)1323 410335 : Fax: +44 (0)1323 646905
Email: [log in to unmask] : Website: www.plasa.org
Join one of the largest trade communities in the industry.
www.plasa.org
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]]On Behalf Of Kallin, Dan
Sent: 01 March 2006 14:39
To: [log in to unmask]
Subject: Re: [LF] Don't be left out on the Next RoHS
I am assuming Nic means the 200K unit criteria. Based on my read of the
directive it is not company specific, it is product specific across the
EU.
The enforcement is through the CE mark and or certain eco labels.
For example, if more than 200,000 computers or washing machines are sold
in the EU in a year the member states will need to develop "implementing
measures" to assure that the those categories of EUPs have a CE mark or
certain eco labels. In order to get the CE mark / label, the
manufacturer will need to demonstrate conformity as described in Article
8 and the appendices (which allows for certain certified EMS).
In My Honest Opinion, unlike the straight forward and short RoHS
directive, this directive is long, confusing and convoluted. You will
need to read it a few times before you can even think of the questions
to ask your lawyer!~
There are provisions to codify existing voluntary agreements.
Does anyone know if this is passed under the single market provision
like RoHS or will member states be able to create their own rules like
WEEE?
Talk about Alice in Wonderland meets Rollerball!
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 Nic Bowker
Sent: Wednesday, March 01, 2006 5:13 AM
To: [log in to unmask]
Subject: Re: [LF] Don't be left out on the Next RoHS
Don't forget the de-minimis level though.
Can anyone clarify if this is per product line of a company or per total
company output.
Nic Bowker
Technical Resources Adviser
PLASA Ltd.
38 St Leonards Road, Eastbourne, East Sussex, BN21 3UT, UK.
Tel: +44 (0)1323 410335 : Fax: +44 (0)1323 646905
Email: [log in to unmask] : Website: www.plasa.org
Join one of the largest trade communities in the industry.
www.plasa.org
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]]On Behalf Of Tempea, Ioan
Sent: 27 February 2006 14:17
To: [log in to unmask]
Subject: Re: [LF] Don't be left out on the Next RoHS
Hi Fern,
did I get it right: the directive actually wants to regulate the energy
consumption of finished products during their life cycle, not covering
the wasted energy during the manufacturing of the product. In this case,
they (EU) are not contradicting RoHS, but maybe trying to balance the
odds: we waste more during manufacturing, but we save during operation.
I wonder if there will be any Design for EuP guidelines.
Just a thought and wishing you well,
Ioan
> -----Original Message-----
> From: Leadfree [SMTP:[log in to unmask]] On Behalf Of Fern Abrams
> Sent: Saturday, February 25, 2006 12:09 PM
> To: [log in to unmask]
> Subject: [LF] Don't be left out on the Next RoHS
>
> EuP: Coming soon from the Government that Brought you RoHS
>
> Not content to rest on its laurels with the upcoming compliance
deadline
> for the Restriction on Hazardous Substances Directive (RoHS), The
> European Union is beginning work on the implementation of its next
> Eco-Directive, the "Directive on the eco-design of Energy-using
> Products," or EuP for short. EuP, whose scope applies to all energy
> using devices, is intended to provide a framework for developing
EU-wide
> rules for eco-design. Under EuP, the Commission will enact
implementing
> measures on specific products and environmental aspects such as energy
> consumption, waste generation, water consumption, extension of
lifetime.
>
>
>
>
> The European Union Commission recently published an invitation for
> experts to apply for the "Consultation Forum" on implementing measures
> for the EuP. The task of the group of experts is to contribute to the
> definition and review of the implementing measures, to monitor the
> efficiency of the established market surveillance mechanisms and to
the
> assessment of voluntary agreements and other self-regulatory measures
> taken in the context of the Directive. The group of experts will be
> composed of a maximum of 50 members, including one representative from
> each Member State and acceding country; it will be open for observers
> from candidate and EFTA countries. The stakeholders consultation is
open
> to US companies with established operations in the EU.
>
>
>
> For more information on the consultation forum, click on
> http://europa.eu.int/comm/enterprise/eco_design/consforum.htm
> <http://europa.eu.int/comm/enterprise/eco_design/consforum.htm> or
> contact Robert Straetz at [log in to unmask]
> <mailto:[log in to unmask]> or 202-482-4496.
>
>
> Fern Abrams
> Director of Environmental Policy
> IPC - The Association Connecting Electronics Industries
> 1901 North Moore Street, Suite 600
> Arlington, VA 22209
> (703) 522-0225
> fax (703) 522-0548
> http://www.ipc.org <http://www.ipc.org/>
>
>
>
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