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» Hatrack River Forum » Active Forums » Books, Films, Food and Culture » Hey Kama... EU stuff... ROHS/WEEE

   
Author Topic: Hey Kama... EU stuff... ROHS/WEEE
BannaOj
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Have you done any work or heard of WEEE/RoHS directives in the EU?

To anyone else who lives in Europe... As an ordinary person, is it actually affecting anyone there? Has there been any publicity on this directive at the layman's level? Or, is it just something that industry is having to deal with?

AJ

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fugu13
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The only part of the WEEE directive that really applies to "private households" is the requirement that member states make it at least free to return WEEE. Given that member states were slow in implementing even the basic frameworks for the WEEE directive, I suspect the visibility to the typical citizen is virtually nil.
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Kama
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had to google it. I think fugu has it right. [Smile]
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BannaOj
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*sigh* yeah, things just hit the fan here at work, cause the UK is cracking down on the first of July. Of course no one really bothered to start implementing before the deadline and none of our customers bothered to tell us that we were subject to this regulation...

AJ

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fugu13
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Silly companies. The directive's been around something like three years, and member states have been implementing the framework since last year (late, but still a decent bit ago).
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BannaOj
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of course until they actually realize that everyone's serious about fines... Plus I think the EU fined the UK for non complaince already.

And the directive is now being interpreted much more broadly than it was previously thought. Therefore, even though we make nothing electrical, because our seals go into electrical pumps that just *might* be under the directive (we never completly know exactly where our seals will be installed.)

AJ

[ June 30, 2006, 03:17 PM: Message edited by: BannaOj ]

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fugu13
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I don't know what the UK's trying to pull, but the directive's not exactly ambiguous. I mean, the listing of applicable appliances is pretty explicit. Its likely the UK is expanding on the reach of the directive somewhat, trying to spread responsibility from just the companies making the appliances. The directive most definitely doesn't say anything about the parts in "electrical and electronic equipment".
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BannaOj
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no... it isn't that explicit... there are large grey areas.

http://www.rohs.gov.uk/DecisionTree.aspx?id=12
http://www.rohs.gov.uk/DecisionTree.aspx?id=21

So, our seals go into pumps, that may or may not be used in "fixed industrial equipment" Particuarly since the pump is a component that isn't necessarily fixed. It also depends on said size of pump.

And pumps can be placed "on the market as a single functional or commercial unit"

Not to mention that we have seals that go into airconditioners, refrigerators, washing machines diswashers etc...

AJ

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BannaOj
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Here's another little gem:
quote:
Sub assemblies are not final products and are therefore outside the scope of RoHS enforcement. However, the products that the sub assemblies form part of will usually need to comply, thus requiring the sub assemblies to be RoHS compliant.

As a sub assembly supplier you are likely to be asked for compliance data from your customers. You in turn may need information from your suppliers. The level of effort and detail you provide is a commercial decision. The product suppliers have a challenging task in ensuring RoHS compliance and they are likely to value your support.

more...
quote:
Producers due diligence

If you produce sub assemblies or components, your products fall outside the scope of RoHS.

However, it is very likely that the finished products being produced further down the supply chain will need to comply. Your customers are likely to require assurance that your products meet the RoHS requirements for maximum concentration values for the restricted materials and will need documentary evidence to support this assurance.

Where a product fails to meet the requirements of the RoHS regulations and one of your products is identified as at fault, there is potential for the final producer to prove the fault lies with their suppliers rather than with themselves.


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BannaOj
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Actually it's just that seal applications are probably one of the most ambiguous grey areas in the mess.

Sometimes lead is used in the curing process of rubber components. It's known as "Litharge curing" This gives you some fantastic properties that can't be obtained any other way.

We also do have chromate coatings, that aren't necessarily hexavalent. However, the detection methods they are using such as XRF (which I have extensive experience with) are just detecting "Chromium" and rejecting, rather than examining whether it's hexavalent chromium (nasty) or Trivalent chromium (not nasty)

AJ

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