RoHS Compliance in 2017
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Transcript of RoHS Compliance in 2017
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EU RoHS Directive
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Today’s Moderator
Madison AdamsAssent ComplianceCompliance Services
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INTRODUCTION
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Assent Product SuitesOur Market Leading Platform
Ethical Sourcing
Materials Management
Supplier Information Management
InspectionsConfigurable Surveys & Declarable Substance
Lists
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Today’s Presenter
Valerie KuntzAssent ComplianceSubject Matter Expert — Materials Management
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Feature PresentationPRESENTER, TITLE & COMPANY Feature PresentationEU RoHS Directive
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Agenda
EU RoHS 2
Scope
Exemptions and Modifications
Showing Compliance
The Future of RoHS 2
Summary
Questions
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Regulation: 2011/65/EU RoHS 2 - Restriction of the use of certain hazardous substances in electrical and electronic equipment, replacing Directive 2002/95/EC
Substances & Threshold:⬥ Cadmium(Cd) and its compounds: 0.01%⬥ Mercury and its compounds: 0.1%⬥ Lead(Pb) and its compounds: 0.1%⬥ Hexavalent chromium (Cr6+) and its compounds: 0.1%⬥ Polybrominated biphenyls (PBB): 0.1%⬥ Polybrominated diphenyl ethers (PBDE): 0.1%
Included after July 22, 2019 per Directive (EU) 2015/863 (RoHS 3.0):⬥ Bis(2-Ethylhexyl) phthalate (DEHP): max 0.1%⬥ Benzyl butyl phthalate (BBP): max 0.1%⬥ Dibutyl phthalate (DBP): max 0.1%⬥ Diisobutyl phthalate (DIBP): max 0.1%
Effective Date: January 2, 2013
EU RoHS 2
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EU RoHS 2
Included Products:
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Excluded Products:
⬥ Industrial Category 9 products (until July 22, 2017)⬥ Category 11 products (until 2019 RoHS 2.1)⬥ Military/security equipment⬥ Equipment designed to be sent into space⬥ Equipment designed to be part of non-scope equipment⬥ Large-scale stationary industrial tools (LSSIT)⬥ Large-scale fixed installations (LSFI)⬥ Transportation vehicles⬥ Non-road mobile machinery (NRMM)⬥ Active implantable medical devices⬥ Photovoltaic panels⬥ Research and Development equipment
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EU RoHS 2 ExemptionsExemptions:EU RoHS exemptions were updated and expanded with the approval of EU RoHS 2 included in Annex III and IV of the directive and are applicable to included products.
⬥ Annex III impacts all Categories 1 to 11⬥ Annex IV impacts Categories 8 and 9
Exemption Expiration Time Frame:Expiration dates can vary depending on final use of the product.
⬥ Categories 1 to 7, 10 and 11 have a validity period of up to five years⬥ Categories 8 and 9 have a validity period of up to seven years⬥ The validity periods are to be decided on a case-by-case basis and may be renewed⬥ Categories 8 and 9 are also broken down further into in vitro medical devices and
industrial monitoring, and control instruments for which different implementation and expiration dates exist
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Exemption Expirations & ModificationsCurrent Exemption Expiration Extensions:Several Annex III exemptions scheduled to expire on July 22, 2016 were requested to be extended and are currently under consideration by the EU Commission. A decision is expected sometime in early 2017.
Exemption Modification Process:The exemption list can be requested to be modified. These modifications can include:
⬥ A New Exemption⬦ Applications related to electrical and electronic equipment (EEE) newly coming into scope⬦ New applications with an aspect of innovation⬦ “Old” applications — applications that have either already expired or been rejected previously
⬥ Change ⬥ Renewal ⬥ Removal
Note: any request for review of an existing exemption can lead to its removal
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Exemption Modification Process
Oko-Institut, "The RoHS Directive: Exemptions and Related Aspects", EDIF ERA Conference EEE and the Environment 2015, November 11-12, 2015.
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Showing Compliance
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◆ Declaration of Conformance (not a specific form)
◆ Industry Standard (IPC-1752, IEC 62474, etc.)
◆ CE marking can be placed on products that are
compliant and meet the other appropriate
regulations or directives required for CE marking
COMPLIANCE
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◆ On Company Letterhead ◇ Needs to indicate the declaration is an official company communication of the
employee making the declaration ◆ Includes the proper RoHS Directive legislative reference ◆ Includes unique reference to parts or products being covered by the declaration ◆ Declares Compliance Status
◇ Compliant (does not contain substances above threshold)◇ Compliant by Exemption (one or more exemption(s) apply and must be disclosed)◇ Non-Compliant (contains one or more substances above threshold where an exemption
does not apply)◆ Declares Exemption (if applicable) per part or product utilizing the exemption◆ Signed by appropriate individual (name, contact, title)◆ Dated
Showing Compliance — Declaration of Conformance
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IPC-1752A: Materials Declaration Management Standard (with Amendments 1 & 2). Latest revision: February 2014. It is a materials declaration standard for companies in the supply chain to share information on materials in products. The standard is supported by an XML schema and a data model.
Showing Compliance — Industry Standards
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IEC 62474: Material Declaration for Products of and for the Electrotechnical Industry. It provides an international standard for the exchange of material composition data and provides requirements for material declarations. The standard is supported by an XML schema and a data model.
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Showing Compliance — (CE) Marking
⬥ CE (Conformité Européenne) marking is a mandatory conformity mark for certain products sold within the European Economic Area (EEA).
⬥ CE marking is a manufacturer's declaration that the product meets the requirements of all applicable EU directives.
⬥ The mark consists of the CE logo and, if applicable, the four-digit identification number of the Notified Body involved in the conformity assessment procedure.
⬥ The CE mark states to European customs that a product meets the product compliance standards required for EEA market access.
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The Future of RoHS 2.0
⬥ Q1’17 Currently expired exemptions with request for extension to be decided by European Commission
⬥ July 22, 2017
⬦ Category 9 industrial monitoring and control instruments are in scope
⬥ January 2018
⬦ Exemption requests to be submitted to cover RoHS 2.1 and RoHS 3.0
⬥ July 21, 2019
⬦ 4 phthalate substances restricted (RoHS 3.0)
⬥ July 21, 2019
⬦ Category 11 (all other electronics) are in scope (RoHS 2.1)
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◆ EU RoHS 2 went into effect January 2, 2013.
◆ Impacts EEE (Electrical and Electronic Equipment) broken into 11 categories with implementation delays for certain categories and exclusions for certain types of products.
◆ Requires providing, at minimum, Declaration of Conformance to downstream customers and CE marking on the product.
◆ Includes several exemptions based on use that allow the substances to be in the product for a period of time.
◆ Exemptions can be modified (added, changed, extended or removed).
◆ Changes are coming into effect in the near future that will impact many more products.
Summary
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Upcoming Events: Webinars & Conferences
Learn more about Assent events:www.assentcompliance.com/events
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[Webinar] Compliance Essentials: Materials ManagementTuesday, January 31st | 1 PM EST
[Webinar] Chemical Disclosure Program for Children's ProductsThursday, February 2nd | 1 PM EST
Upcoming Educational SummitsFebruary 8th, 2017 | San Jose
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Q&A Discussion
Questions?
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