Jon,

Thanks for posting the link to the "Korea RoHS" regulation. It seems to
have a lot more to do with WEEE than RoHS, and the details seem to be
relegated to a "Presidential Decree,"  to which it refers 32 times. Do
you know if this decree has been published and translated? I didn't see
any reference to "homogeneous substance," but I suppose that too is
covered in the decree.

Paragraph 2 of Article 9 at least refers to the issue of analytical
techniques, but not in a way that offers any help: "The Ministry of the
Environment and the Ministry of Commerce, Industry and Energy may
jointly determine and publish the Analysis Methods of Hazardous
Substances." As you no doubt know, industry standard techniques for many
of the substances don't exist, and I doubt that the Korean ministries
have determined, let alone published, any analysis methods.

Article 11 on self-declaration is pretty vague. The RoHS directive says
the putting the products on the market constitutes self-declaration of
compliance. What more do the Koreans expect?

The requirements in Article 14 are virtually unenforceable. Who gets to
decide whether a producer or importer has "made an effort"?

 

Gordon Davy 


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