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| 1. |
What is RoHS? |
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RoHS is an acronym for the European Union’s directive to Restrict the use Of certain Hazardous Substances in electrical and electronic equipment. The simple purpose of RoHS (EU Directive 2002/95/EC) is to restrict the use of six known hazardous substances within electrical and electronic equipment (EEE), thereby contributing to the protection of human health and the environment. While the purpose is clear, the RoHS directive itself is more complex
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| 2. |
What is the difference between lead-free and RoHS compliant? |
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While lead (Pb) is the most widely used toxic substance in electrical and electronic equipment (EEE), the term "lead-free" is often wrongly adopted to refer to all of the substances specified in the Restriction of Hazardous Substances (RoHS) Directive. However, RoHS restricts a total of six substances - lead, mercury, cadmium, hexavalent chromium, PBB and PBDE. To be truly compliant with this legislation, the presence of each of these substances must be reduced below their proposed maximum concentration values (MCV).
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| 3. |
When will the directive take effect? |
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On july 1st, 2006 all electronic and electrical equipment sold to the European market must comply with EU Directive 2002/95/EC. There will be no exceptions made for inventory manufactured prior to the implementation date and which is not RoHS compliant.
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| 4. |
Does the directive apply exclusively to products manufactured and sold in Europe ? |
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The directive applies to all products sold in Europe, irrespective of their place of manufacture. Directives such as the RoHS and WEEE directives apply to all the Member States of the European Union. They must be transposed into the national laws of each of those states. According to article 95 of the legal base, RoHS must be transcribed into national laws without any change. WEEE instead defines minimun requirements that each States has to fulfil but can also modify to fit its own regulations.
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| 5. |
What exactly is the definition of the “market” for which this directive applies? |
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The “market” refers to the European single market. However, as EU directives also apply to the European Economic Area (EEA), which includes Iceland, Liechtenstein and Norway, these aforementioned countries would also fall within the scope of this market definition.
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| 6. |
What does “putting a product on the market” actually mean? |
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The European Commission suggests that a product is placed on the Community market when it is made available for the first time1. This is considered to take place when a product is transferred2 from the stage of manufacture with the intention of distribution or use on the Community market.
1 The phrase “for the first time” does not imply that RoHS is applicable only to new products. For example, a product originally sold outside of the EU, which subsequently enters the EU market after the july 1st, 2006 deadline, (either as purchased or free-issued product) would fall within the scope of the RoHS directive, even though it may in fact be technically “used”.
2 The term “transferred” is key in interpreting this expression. In essence, the transfer of a product takes place when it passes from the manufacturer (or his representative) to the importer, distributor or end user. There does not need to be a financial transaction for this occur – product that is donated, or given away, such as the case of a sample or prototype, is still considered to have been placed on the market.
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| 7. |
What is a homogeneous material ? |
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This would be a material that cannot be mechanically separated into different materials. So, it would have “uniform composition throughout”. Examples of “homogeneous” materials : plastics, ceramics, glass, metals, alloys, paper, board, resins, coatings. An assembled Connector is NOT homogeneous, but the component parts of this connector such as contact alloys, pure tin plating, metal shells and plastic moulded housings would be. Example : Semi-conductor housing composed of 6 homogeneous materials. 
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| 8. |
What is meant by large-scale stationary industrial tool ? |
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Large-scale stationary industrial tools do not come within the scope of the directive, and it is therefore important to understand clearly what is covered by this expression.
A large-scale stationary industrial tool is a machine or system consisting of a combination of finished products and/or components, each of which is designed to be used only in fixed industrial applications; its installation is performed by professionals, in a given place, within a set of machinery or in an industrial building to perform a specific task.
The products incorporated under these conditions are not subject to the RoHS directive except if they come within the scope of the Directive and can also be used as an autonomous function. It is important to distinguish between large-scale stationary industrial tools and small tools that are finished products, having a direct function, sold in the market as a commercial unit, usable anywhere, and powered from a general-purpose power outlet. For example, a portable electric drill must be in compliance, whereas a machine tool designed for a specific workshop will be considered as a stationary industrial tool and will therefore be outside the scope of the directive.
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| 9. |
Are the RoHS and WEEE directives related? |
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Yes. The WEEE Directive aims to raise levels of recycling of WEEE and encourage products to be designed with dismantling and recycling in mind. A key part of this is to make manufacturers and importers of electrical and electronic equipment responsible for meeting the costs of the collection, treatment and recovery of WEEE. If products are designed with this in mind, there is an opportunity to reduce these costs. The RoHS Directive fits into this by reducing the amount of hazardous substances used in products. This reduces the risks to recycling staff and means that less special handling is required, again leading to a reduction in recycling costs.
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