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RoHS Recast: What’s in store for 2.0?

By A.J. Guikema

Anything not exempted from the scope of ‘Electrical and Electronic Equipment’ is subject to the Recast provisions. An entirely new eleventh category will be added to Article 2. Not a part of RoHS legislation, but closely linked to it, is EU CE marking.

THE EUROPEAN PARLIAMENT VOTED November 24, 2010 to adopt the latest proposed amendments to the RoHS Directive. The EU’s RoHS Recast may be transposed into member state law as early as October 2012.

This Recast will bring large families of previously excluded products into the scope of the RoHS Directive.

Some of the most notable changes will be in the list of ‘in-scope categories’ currently found in Article 2 of the existing Directive.

Two of the existing ten WEEE categories will become subject to RoHS and an entirely new eleventh category will be added to Article 2.

Categories 8 (medical devices) and 9 (monitoring and control equipment) had previously benefited from exempt status but will be brought into scope three years after the date of entry into force of the Recast.

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However instead of a three year wait, there will be a delayed entry-into-scope for the special cases of in-vitro medical devices (five years) and industrial monitoring and control equipment (six years).

The other major change to Article 2 is the addition of a new Category 11 to the Directive.

This new category serves as a catch-all: “Other electrical and electronic equipment not covered by any of the categories above.”

Because of this very broad categorization, one should refer back to the existing definition of ‘Electrical and Electronic Equipment’ and realize that anything not explicitly exempted from that scope will be subject to RoHS under the provisions of the Recast.

Products in this category have eight years after the date of entry into force to comply with RoHS.

That’s not all …
Another significant change from the Recast involves the need to explicitly declare conformity with the law. Currently, when a producer places a product on the market in the EU it is assumed to be RoHS compliant although there is no official ‘RoHS-compliant’ logo to indicate this.

Although no declaration of conformity is required, there is an expectation that documentation of compliance be produced upon request of enforcement authorities.

The RoHS Recast now will require a declaration of conformity created by the manufacturer stating that the requirements have been met.

There are specific elements that must be included in the document; such as, but not limited to: unique identification number, name / address of manufacturer, references to technical specifications, signature …

Not a part of the RoHS legislation, but now very closely linked to it is the issue of CE marking in the EU (Regulation EC No 768/2008).

This is a marking to indicate product conformity with applicable harmonized legislation.

If the product complies with the new RoHS, it must have a CE marking, thus tying the RoHS and CE marking requirements very closely together.

Meanwhile, there are a variety of changes in definition in RoHS 2.0. One of the most noteworthy changes in definitions for RoHS Recast is the increased detail regarding the definitions of large-scale stationary industrial tools and large scale fixed installations.

This was important in order to clarify which types of tools and installations were exempt as there were many borderline cases that were not clear under the old definitions.

The Recast also provides new criteria for the application, granting, renewing and deletion of exemptions.

These criteria describe the processes for manufacturers or their authorized representatives to make formal requests for these types of changes. A new Annex V provides the information required on an application for exemption and for an application for renewal of an existing exemption.

Also under RoHS 2.0, all exemptions will have expiration dates, but may be renewed.

Applications must be filed 18 months prior to the expiration date of the particular exemption. The European Commission is then required to give its decision on the renewal six months prior to the expiration date.

RoHS 2.0 was developed based on extensive feedback from industry and other stakeholders. While there was debate about the direction for this Recast, many of the provisions promise to streamline and improve the regulation, implementation and enforcement of this requirement.

Hopefully the lessons that have been learned over the past seven years have led to changes that constitute a step forward toward a new, improved RoHS.

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