Transcript ERA Technology Ltd EU REACH and related legislation

ERA Technology Ltd
RoHS category 9
Dr. Paul Goodman
[email protected]
1
17/07/2015
© ERA Technology Limited
Agenda
•
History of RoHS recast
•
Category 9 scope and compliance deadlines
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Industrial monitoring and control instruments
• Definition of professional users
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© ERA Technology Limited 2012
History
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ERA study carried out in 2006 – Is it possible to include categories 8 & 9
in scope of RoHS?
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Conclusion, yes it was possible, but industry needs time
•
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Most category 9 by 2012 but test equipment by 2015
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Commission added two years to deadlines after industry lobbying (so 22
July 2014 and 2017)
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But suggested definitions of test equipment were too ambiguous so EC
generously broadened scope of category 9 EEE having later compliance
deadline as all “industrial monitoring and control instruments”
RoHS recast adopted with categories 8 and 9 in scope
•
3
Definition of industrial monitoring and control instruments included in
directive.
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What is in category 9? – PG opinion
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Items listed in indicative examples of category 9 of the WEEE directive
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Multimeters – monitors voltage, etc. Many designs, performance and
complexity - held and benchtop
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Oscilloscopes – main function is monitoring
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Clamp meters - monitor
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Signal generators – control signal output
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Bench top power supplies – types that provide an accurately controlled
current or voltage (note multipurpose power supplies / battery chargers
are category 6)
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Note that some laboratory equipment does not monitor or control so is
not in category 9 (e.g. grinders, centrifuge – these are tools)
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© ERA Technology Limited 2012
Category 9 compliance dates
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Category 9 equipment placed on the (EU) market from the 22 July 2014
must comply with RoHS2, except:
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Industrial monitoring and control instruments placed on the market from
22 July 2017
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Designed for exclusive use by industry and professionals
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“Professionals” is not defined by RoHS
•
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Widely understood to be a person carry out their employment activity –
e.g. employees, workers, contactors, consultants, etc.
EEE designed to be used by both professionals and non-professionals must meet
the earlier compliance deadline. Non-professionals includes:
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Consumers
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College students
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Undergraduates and probably also post-graduates
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NMO have said that equipment in public buildings, such as smoke alarms, must
comply with earlier deadline, as the buildings (and therefore the EEE) are used by
non-professionals
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© ERA Technology Limited 2012
Examples
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Multi-meter
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Simpler handheld designs are used by consumers so 2014
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Intermediate complexity – may be used by some consumers and are also
likely to be used by undergraduates so 2014
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The most complex (and expensive) bench-top designs that are
specifically for professional users – 2017
Oscilloscope
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Simpler models are used by students at colleges, Universities so need to
comply from 2014. These include fairly complex designs.
•
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Most advanced designs that are designed only for use by professionals
comply from 2017
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Consider intended users – marketing of products
Consider price, complexity, training needed – ask will undergraduates use
these?
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© ERA Technology Limited 2012
Conclusions
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RoHS recast includes category 9 from 2014
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Industrial monitoring and control instruments from 2017
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But definition of industrial monitoring and control instruments is limited
to equipment designed for exclusive use by professionals
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Note that some quite advanced equipment supplied to Universities is
regularly used by graduates and/or postgraduates
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Directive does not define “professional” so Member State market
surveillance authorities will make their own interpretations.
Therefore these are NOT designed for exclusive use by professionals
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© ERA Technology Limited 2012
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Any Questions?
17/07/2015
© ERA Technology Limited 2012