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RoHs (Restriction of Hazardous Substances), and CE Mark

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This is a quick explanation of terms, and related requirements to which those terms refer. The regulations refer to European Union (EU) rules that will affect US manufacturers exporting product to that market. Terms and EU initiatives that describe this and related regulations are as follows:

RoHS (Restriction on certain Hazardous Substances)

An expansion of CE Mark coverage, and is meant as a device to control materials that are deemed hazardous in any significant concentration, in any country in Europe. By control we mean preventing introduction of new material, and control as well as disposal of existing as well as future listed substances.

RoHS takes effect July 1, 2006. As with CE Mark, the manufacture and their agents bear responsibility for compliance. The liability and requirement for action to clear up any discrepancies will lie with the manufacturer of the product, as well as with the appointed agent.

CE Mark

"Conformite' Europene", meaning European Conformity.

1. CE Mark on a product is a manufacturer’s declaration that the product complies with all the essential requirements of the relevant European health, safety and environmental protection legislations. These are identified in practice by Product Directives.

2. CE Mark on a product indicates to government officials that the product may be legally placed on the market in their country.

3. CE Mark on a product ensures the free movement of the product with the EFTA and the European Union (EU) single market (total, 28 countries)

4. CE Mark rules permit the withdrawal of non-conforming products by customs and enforcement/vigilance authorities.

The manufacturer, and/or their authorized agent are responsible for compliance with all components that make up their product offering.

WEEE (Waste Electronic and Electrical Equipment)

WEEE is a requirement that such items as computers or toasters can no longer simply be land-filled, but must be recycled by the original supplier.

Note!

Some States in the US, notably California, are considering parts of these regulations as a way to control land-fill growth, among other things.

Background

From July 1, 2006, new electrical and electronic equipment place on the market in the EU shall not contain substances known to be harmful to humans and to animal life. These materials constitute the list:

  • Lead (Pb)
  • Mercury (Hg)
  • Cadmium (Cd)
  • Hexavalent Chromium 6 (CrVI)
  • Certain Brominated flame retardants (BFR’s)
  • Polybrominated biphenyls (PBB’s)
  • Polybrominated diphenyl ethers (PBDE’s)

The maximum concentration values are .1% by weight (1000 ppm) in “homogeneous materials” for materials on the list, except cadmium, which is limited to .01% (100PPM).  These limits will apply to all components within the equipment, unless otherwise exempt.

The EU Waste Electrical and Electronic Equipment directive (WEEE) applies to a wide range of electronic and electric products. WEEE encourages the collection, treatment, recycling and recovery of waste or discarded equipment in the above categories. Producers and importers are responsible for financing the collection, treatment and recovery of WEEE. Reference the EU Waste Electrical and Electronic Equipment (WEEE) directive 2002/96/EC, as amended by 2003/108/EC.

The following products are affected by WEEE:

  • Large household appliances
  • Small household appliances
  • IT and Telecommunications equipment
  • Consumer equipment
  • Lighting equipment
  • Electronic and electrical tools
  • Toys, Leisure and Sport equipment
  • Medical devices
  • Monitoring and control instruments
  • Automatic dispensers

The national governments are continuing to pursue clarification of the breadth of these categories. Further updates will be published as by the EU.

The following products are, for the present, not included, or are exempt from the scope of WEEE:

  • Implanted and infected products
  • Large scale stationary industrial tools
  • Military products
  • Automotive products
  • Aerospace/aircraft products
  • Surface transportation products

As noted, these regulations will be reviewed and updated. The schedule for these updates is likely to be frequent. For those companies who are now in the affected markets, or are contemplating entry into those markets in whatever capacity, the following resources are suggested for information, and for detailed support.

Resources

Allen Patch
Director, U.S. Export Assistance Ctr
US Dept of Commerce
Partnership Building
700 Locust St. Ste. 100
Des Moines IA 50309
Tel/Fax 1-515-288-8614/1437
allen.patch@mail.doc.gov
http://www.buyusa.gov/europeanunion/

Yvonne Halpaus
QNET LLC
PO Box 527
Elk River MN 55330
Tel/Fax 1-763-441-0899/0898
qnet@ce-mark.com
www.cemark.com