Dr. Paul Goodman [email protected]

ERA Technology Ltd RoHS category 9

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Agenda

• • • History of RoHS recast Category 9 scope and compliance deadlines • Industrial monitoring and control instruments Definition of professional users © ERA Technology Limited 2012

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History

• • • ERA study carried out in 2006 – Is it possible to include categories 8 & 9 in scope of RoHS?

Conclusion, yes it was possible, but industry needs time • • • Most category 9 by 2012 but test equipment by 2015 Commission added two years to deadlines after industry lobbying (so 22 July 2014 and 2017) But suggested definitions of test equipment were too ambiguous so EC generously broadened scope of category 9 EEE having later compliance deadline as all “industrial monitoring and control instruments” RoHS recast adopted with categories 8 and 9 in scope • Definition of industrial monitoring and control instruments included in directive.

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What is in category 9? – PG opinion

4 • • • • • • • Items listed in indicative examples of category 9 of the WEEE directive Multimeters – monitors voltage, etc. Many designs, performance and complexity - held and benchtop Oscilloscopes – main function is monitoring Clamp meters - monitor Signal generators – control signal output Bench top power supplies – types that provide an accurately controlled current or voltage (note multipurpose power supplies / battery chargers are category 6) Note that some laboratory equipment does not monitor or control so is not in category 9 (e.g. grinders, centrifuge – these are tools) 29/04/2020 © ERA Technology Limited 2012

Category 9 compliance dates

5 • • • Category 9 equipment placed on the (EU) market from the 22 July 2014 must comply with RoHS2, except: Industrial monitoring and control instruments placed on the market from 22 July 2017 • Designed for exclusive use by industry and professionals • • • • • “Professionals” is not defined by RoHS • Widely understood to be a person carry out their employment activity – e.g. employees, workers, contactors, consultants, etc.

EEE designed to be used by both professionals and non-professionals must meet the earlier compliance deadline. Non-professionals includes: Consumers College students Undergraduates and probably also post-graduates NMO have said that equipment in public buildings, such as smoke alarms, must comply with earlier deadline, as the buildings (and therefore the EEE) are used by non-professionals 29/04/2020 © ERA Technology Limited 2012

Examples

6 • • • Multi-meter • • • Simpler handheld designs are used by consumers so 2014 Intermediate complexity – may be used by some consumers and are also likely to be used by undergraduates so 2014 The most complex (and expensive) bench-top designs that are specifically for professional users – 2017 Oscilloscope • Simpler models are used by students at colleges, Universities so need to comply from 2014. These include fairly complex designs. • Consider intended users – marketing of products Most advanced designs that are designed only for use by professionals comply from 2017 • Consider price, complexity, training needed – ask will undergraduates use these?

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Conclusions

• • • • RoHS recast includes category 9 from 2014 Industrial monitoring and control instruments from 2017 But definition of industrial monitoring and control instruments is limited to equipment designed for exclusive use by professionals • Directive does not define “professional” so Member State market surveillance authorities will make their own interpretations.

Note that some quite advanced equipment supplied to Universities is regularly used by graduates and/or postgraduates • Therefore these are NOT designed for exclusive use by professionals 29/04/2020 © ERA Technology Limited 2012

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Any Questions?

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