Ancillary parts
All parts sold as part of the product are capable of being considered part of the product for the purposes of RoHS. Whether a part is considered part of the product may depend upon such considerations as interdependence, expected inclusion in WEEE and product description. This may include items such as: - Playing pieces or dice in a game requiring electricity to play
- Cases supplied with the product (example: a protective case supplied with a power tool)
It does not include items such as: - Packaging
- Instruction manuals
- Consumables such as printer cartridges, jigsaw blades and drill bits
|
Cables
The present Commission view is that cables both included within EEE and sold separately do fall within RoHS. The DTI are in discussion with the commission over this but until there is a change the Commission view stands.
|
Does packaging used for a product need to comply with RoHS regulations?
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 remain with, the product and may be disposed of with the product may need to comply and must be judged on a case by case basis.
|
Is there a RoHS approved Certificate?
There is no prescribed requirement for certification in the UK. There is only a requirement in the UK that an EEE product ‘producer’ has documentation to demonstrate compliance. Therefore there is no expiry time or other prescribed approaches to the format of certificates. Please read Annex D of the linked document.
RoHS Guidance notes February 2008 edition
|
RFID chips and security tags
There is a range of chips and tags used for stock control and retail security. These are often adhered to the packaging of other products. These are considered products in themselves and EEE used by the business. They are not part of the product packaging of the tagged products. Therefore in our opinion RoHS requirements apply.
|
Semiconductor Evaluation Boards
The term Evaluation boards covers a broad range of products from some fairly simple products to fully integrated complex systems. In most cases an evaluation board is effectively a single board computer allowing connection of peripherals and/or input devices to facilitate the programming and testing of chips. Therefore most evaluation boards are included under Category 3 IT Equipment of the WEEE directive and must therefore comply with RoHS. On rare occasions these boards may be considered consumables and fall outside the scope of RoHS as described in the commission FAQ http://europa.eu.int/comm/environment/waste/pdf/faq_weee.pdf .
|
Uninterruptible Power Supplies (UPS)
UPS are commonly used in the IT industry and as such would normally be considered to fall under WEEE Category 3. However, the function of a UPS is to monitor the supplied power and control any fluctuations in that supply. Therefore the most appropriate category would be WEEE Category 9 which is outside the scope of RoHS.
|
We are mostly RoHS compliant but there is one part we have difficulty sourcing. Can we continue to use?
We cannot advise you that you can break the law. From the 1 July 2006 all products you place on the market must be compliant. You place non-compliant product on the market at your own risk.
|
Weighing Machines
We have spoken with DTI and looked at carefully the applicability of RoHS regulations to weighing instruments. Our view is: - Scales and weighing machines used in a domestic environment (for example, kitchen and bathroom scales) are covered by the regulations and must comply
- Stand alone weighing instruments or primary function weighing instruments/machines used for trade or schedule 3 applications in a professional environment will normally be considered category 9 and therefore exempt.
- Medical weighing instruments are category 8 and therefore exempt
- Weighing instruments that are included in a larger system which has a primary function other than weighing, that fits within another category in the regulations (for example, an EPOS as IT and data control equipment) are included within the scope of the regulations and must comply.
|
What category are GPS units?
GPS systems is an interesting question. The two clear choices are category 9 monitoring and control (location devices) or category 3 as part of a radio network system. We tend towards them being network equipment. Therefore they would be category 3 and need to comply with the regulations. They would not be entitled to use the exemption for lead in solder because failure of a receiver does not effect the network.
|
Who are the Authorities responsible for RoHS outside the UK in another member state?
Please see this attached file ERA Directory supplied with thank by ERA Technology http://www.era.co.uk. This is presently the best concise list of authorities operating within the EU we are aware of. When we become aware of further information we will update this document in partnership with ERA.
|