The National Weights and Measures Laboratory (NWML)has been awarded the contract to set up the UK's national RoHS enforcement body.t published Rohs enforcement guidance document on 31st may of this year.
This Guidance Document has been developed through discussions within the"U RoHS Enforcement Authorities Informal Network" It should be noted that the document is informative and advisory, but has no legal authority. Individual Member State RoHS enforcement authorities are bound by their own national legal structures and can only apply this guidance within the confines of those structures.
Key issues addressed within the Guidance include:
• The underlying principles that might be used to guide RoHS enforcement
• The type of documentation that 'roducers'within the specific definition given in Article 3 of the Directive1) might be advised to keep
• The ways in which Member State enforcement authorities might use such documentation to check for RoHS compliance
• The ways in which sample preparation and analytical testing might be employed to avoid inconsistent enforcement decisions between Member States.
As a result, this document has been developed to provide non-binding guidance on these issues. Faced with the very wide range of products covered by the RoHS Directive, Member State enforcement authorities must - in the first instance-ecide which EEE (electrical and electronic equipment) categories and products they wish to select for further investigation. These decisions will be made following market surveillance activities and could involve one or more of the following criteria:
• Market intelligence;
• Random selection;
• Products known to contain materials of high concern;
• High volume products;
• Short life products;
• Consumer products unlikely to be recycled;
• Notification of concern from external parties;
• Notification of concern from other Member States.
The producers should provide the self-declaration. The guidance documents should list the steps of Rohs compliance , the self-declaration by producers and testing report.
There are two routes in this documents:
Route 1: Typical information relating to the producer' internal system to ensure RoHS compliance
Route 2: Typical information relating to a product'/part'physical attributes that ensures RoHS compliance of a specific product
The document including general document, company compliance guideline and data system, etc, This could include risk assessments, acceptance criteria, purchasing procedures and any other relevant documentation and may be a combination of both process-based and product/part-based documentation.
Route 1 is Process-based Technical Documentation;
Route 2 is Product/Part-based Technical Documentation
Generally speaking, the employment of testing (which could be either nondestructive or destructive) to verify compliance with the requirements of the RoHS Directive will usually be seen as a last resort. In order to obtain conclusive proof of a product's ompliance the RoHS Directive, producers may however choose to carry out analytical testing of homogeneous materials in their products and/or specific components. Enforcement authorities may also choose to carry out such testing to verify the claims of producers in relation to equipment placed on the EU market.
The guidance shows the relevant international organizations are working for drafting criterion and guideline project, the documents will be listed in Rohs directive as annex.
If you want to get more information, please browse http://www.rohs .gov.uk |
