New directives create compliance dilemma

Alan Bird, Sales Manager at Dionics, illustrates the frequently complex relationship between allied legislation.

Determining whether the products you manufacture fall within the scope of new European environmental legislation can be far from straightforward, as the following real life example demonstrates.

One client, a manufacturer of commercial lifts, was exploring the effects the Restriction of Hazardous Substances (RoHS) Directive would have on its new generation of products.

Simultaneously, the company needed to understand the implications the Waste Electrical and Electronic Equipment (WEEE) Directive would place on their end of life products.

As RoHS takes its scope from WEEE, we must first examine the annex of this waste directive to ascertain the scope of RoHS.

There is no category into which large fixed industrial or commercial equipment falls, so the mechanical aspect of the lift may be considered exempt from both directives.

However, it was immediately apparent that a large proportion of the controlling electronics fell neatly into category 9 of the WEEE Directive.

And although RoHS takes its scope from WEEE, it ignores categories 8 (medical devices) and 9 (monitoring and control instruments), which are currently exempt.

So, neither directive implicates the mechanical aspects of the lift.

The electronic elements of the equipment are exempt from RoHS but do fall within the scope of WEEE, thereby imposing producer responsibility for financing separate collection and recycling at the products end of life.

The scope of the WEEE Directive states: "This Directive shall apply to electrical and electronic equipment falling under the categories set out in Annex IA provided that the equipment concerned is not part of another type of equipment that does not fall within the scope of this Directive".

"Annex IB contains a list of products which fall under the categories set out in Annex IA".

In essence, from a WEEE perspective, if something forms part of an exempt piece of equipment, it itself becomes exempt by association.

However, in spite of this valid exemption, the organisation began the transition to RoHS compliant manufacturing, as it was apparent that the landscape of industry around them would be moving towards lead-free.

As a relatively small consumer of electronic components it recognised it would be unable to demand the continued production of the Pb-bearing parts, and this fear of "virtual" obsolescence influenced its decision to "go green".

This is just one example of the level of support available to clients of Dionics unique RoHS Toolkit.

Primarily developed to assist with the complex areas of component compliance, the Toolkit uses simple decision tree methodology backed by experienced specialists to assist in the transition to lead-free manufacturing.

Visitors to www.pb-free.info can take advantage of a free newsletter subscription, ensuring they are kept abreast of important legislative updates to the RoHS Directive.

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