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RoHS Enforcement. Proposed Guidance Document for EU Member State Enforcement Bodies. Background. RoHS Directive - based on Article 95 Does not say how Member States or industry might comply with its requirements UK study (for the TAC) on enforcement - published April 2004

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rohs enforcement

RoHS Enforcement

Proposed Guidance Document for EU Member State Enforcement Bodies

background
Background
  • RoHS Directive - based on Article 95
  • Does not say how Member States or industry might comply with its requirements
  • UK study (for the TAC) on enforcement - published April 2004
  • TAC Workshop on MCVs – July 2004
  • Member State & Industry Workshop – May 2005
guidance key issues
Guidance – Key Issues
  • Principles to support RoHS enforcement
  • Documentation that ‘producers’ should keep
  • How enforcement bodies might use such documentation to check for RoHS compliance
  • How sample preparation and analytical testing could be employed
guidance contents
Guidance – Contents
  • Introduction: Aims, Objectives, Principles & the Enforcement Process
  • RoHS Compliance Documentation
  • Sample & Testing Issues
discussion subjects i
Discussion Subjects - I

Table One: Documentation first, then Analysis

  • Evidence of compliance should – in the first instance - be based on documentation, not analysis. Is that clear?
  • Analysis is seen as a last resort. Should Section 3 be amended to make it clear?

Table Two: Compliance Flowchart

  • (On p. 5). Is it clear and how could it be improved?
discussion subjects ii
Discussion Subjects - II

Table Three: Standards & Confidentiality

  • The IEC standard is referenced at a couple of points within the guidance, (p. 8 & 9). How do we make it clear that this standard is not mandatory?
  • Confidentiality issues. How do we deal with those?

Table Four: Weight Threshold (proposed limit)

  • The 100mg figure for homogenising materials should be employed only when nothing else is possible. Not a loophole.
  • Would a flowchart help?
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