Escolar Documentos
Profissional Documentos
Cultura Documentos
6. Does packaging used for a product need to comply with RoHS regulations?
No. But yes. :) Any packaging that is discarded after purchase of the product is not considered to be part of the
EEE and therefore does not fall within the scope of the RoHS regulations. However, compliance of a case or
packaging that forms part of, or may stay with, the product and may be disposed of with the product may need to
comply; this must be judged on a case by case basis. Think of a sticker commonly left on the bottom of a laptop,
for instance. Or a special piece of packaging attractive to children that a child wants to keep.
Industry intelligence will advise that packaging suppliers and users be sensible: know what's in your packaging.
Declare -- or be ready to declare -- anything that remotely smacks of cadmium, lead, mercury or the other three
primary suspects in the RoHS case. Remember, suppliers can pass you cadmium in paint -- packaging
companies and customers must be on top of their ingredients.
7. What are the rules regarding repairing a product placed on the market prior to 1st July 2006?
The RoHS Directive does not apply to spare parts for the repair, or reuse, of electrical and electronic equipment
placed on the market before 1st July 2006. This is so that old equipment can be maintained with spare parts and
to promote the reuse of old electrical and electronic equipment.
It is permissible to place on the market spare parts - containing the hazardous substances - for the repair of old
equipment (if the latter was put on the market before 1st July 2006). But it is not permissible to repair new
equipment (put on the market after 1st July 2006) with spare parts containing hazardous substances. The
marketing of spare parts containing banned substances for the repair of new equipment would prolong the
existence of hazardous substances in the waste stream and hamper efforts to increase recycling.
8. Are LEDs within the scope of RoHS?
No, but the product containing an LED is within the scope.
LEDs sold individually are considered to be components rather than an electrical product and therefore
are not within the scope of RoHS. However, when being used as part of electrical equipment, LEDs do fall within
scope and therefore should be compliant. For instance, an LED lamp is covered by the Directive. Starts to make
sense, doesn't it.
If not, you may need to contact an expert -- or review the gory details yourself (see #10 below) but it isn't always
pleasant reading and has a similar hue to the U.S. OSHA Federal Registers.
9. Can a company continue to manufacture items it was manufacturing before 1 July 2006 without
modification?
No. Any item of electrical or electronic equipment covered by the RoHS scope that is placed on the EU market
from 1 July 2006 will have to comply, regardless of whether it is one of a line of products that existed before that
date. No grandfather clause, sorry.
10. Where can I find all the (more) gory details?
There is more information to be found on Wikipedia of course, and here and here:
RoHS Directive: http://www.rohs.gov.uk/Docs/Links/RoHS%20directive.pdf
WEEE Directive: http://www.rohs.gov.uk/Docs/Links/WEEE%20directive.pdf