RoHS
My understanding is that it depends on your definition of packaging. If
the packaging remains with the product for the life of the product, for
example a plastic package containing an electric drill, bit and
consumables, then said packaging falls within the scope of the RoHS
legislation. If the packaging is primarily for transportation and
disposed of on receipt then it would fall under the Packaging Directive.
This has been gleaned from conversations with NWML.
REACH
I confess that my approach to REACH is that the legislation controls the
chemicals and substances that we and our supply chain utilise in the
manufacture of our end product. Our responsibility is to ensure that our
supply chain is aware of its responsibilities under REACH and that we
are not impacted by a chemicals and substances being used in an manner
unforeseen and therefore unregistered by the originator of the chemical
or substance.
Michael
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of James, Chris
Sent: 14 May 2009 18:04
To: [log in to unmask]
Subject: Re: [LF] Does REACH include packaging?
RoHS does not apply to packaging - where in the RoHS scope does it say
it does?
REACH is applicable to chemicals and substances. Yes it does have a
requirement for down stream user awareness but a carton per se is not in
the scope of REACH either.
Chris
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Scott Xe
Sent: 14 May 2009 17:55
To: [log in to unmask]
Subject: Re: [LF] Does REACH include packaging?
Chris,
REACH is controlling the end product rather than materials. If it
applies to materials making the carton, lots of chemicals may be
disregarded.
For
example, the process from tree to paper uses chemicals. The next
process from paper to corrugated card board uses chemicals. The process
from corrugated card board to gift box and carton uses chemicals as
well.
The
same applies to plastic material that from petroleum to plastic parts.
Actually, there is some confusion as there is packaging directive
controlling packaging first then RoHS controlling product itself. Now
REACH controls both.
Scott
-----Original Message-----
From: James, Chris [mailto:[log in to unmask]]
Sent: Friday, May 15, 2009 12:06 AM
To: (Leadfree Electronics Assembly Forum); Scott Xe
Subject: RE: [LF] Does REACH include packaging?
Packaging is covered by the Packaging Directive.
REACH would be more applicable to the materials making the carton, not
the end article. It is obviously in the end users interest to ensure
REACH won't impact the availability of the carton and indeed that all
suppliers back up the chain are cognizant of REACH and their
obligations.
C
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Scott Xe
Sent: 14 May 2009 13:21
To: [log in to unmask]
Subject: [LF] Does REACH include packaging?
Understand the REACH is applicable to article but wonder if it includes
its packaging, i.e., gift box, inner carton and outer carton, etc.
Thanks,
Scott
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