MANAGEMENT + SYSTEMS
RoHS 2: It may affect you…
Some fastener manufacturers and distributors may be unaware that the new RoHS 2 directive is likely to affect their businesses. Jenni Morland, European business process manager at TR Fastenings, looks at some of the implications for the fastener supply chain.
to as RoHS 2 has a far wider scope than the original legislation, affecting many industries outside the electronics sector. In 2003 the EU adopted the original RoHS, which took effect in 2006. The directive was revolutionary when it came into force. It identified six hazardous substances that were either banned or restricted within the production of electrical equipment: namely lead, mercury, cadmium, hexavalent chromium, PBB and PBDE. Eight years on, the legislation has been rewritten and no
B
longer applies just to products with a primary electronic function, such as televisions, computers, washing machines and other
“ The scope of RoHS 2 has radically changed. Fasteners sold to what could previously be seen as non-electronic markets may now fall under the legislation.”
household goods. Instead, with RoHS 2 any product using an electric current needs to be compliant. For example, a manufacturer of reclining chairs would
previously not have had to conform to the original RoHS directive, since the primary function of its product was as a chair, and to work as a chair no electronic current is required. However, under RoHS 2, because one of the intended functions of the chair is for it to recline using an electronic motor, the motor will now need to be compliant in order for the chair to be approved for sale. The scope of RoHS 2 has therefore radically changed.
Distributors and wholesalers need to be aware that fasteners sold to what could previously be seen as non-electronic markets may now fall under the legislation. In addition, even though a
e prepared. The European Parliament and Council formally adopted a revision to the Restriction on Hazardous Substances (RoHS) Directive in July this year. The new Directive 2011/65/EU commonly referred
material may have been RoHS compliant in the past it may not comply with the new directive, since the legislation affects not just the material but the processes it goes through right up to the finished product. For sheet metal manufacturers, this means that stainless steel, previously a compliant material may not adhere to the new directive, due to the passivate finish. All fastener manufacturers, distributors and wholesalers now
need to consider in detail whether the legislation affects them and whether their processes are RoHS compliant. They therefore need to take a long hard look at their processes and risk-assess them. In the past, proof of compliance to RoHS has been difficult to
police. In recent years, compliance authorities in Sweden and the Netherlands carried out checks on electrical products from importers, wholesalers and retailers, and found that around 20% of the products were non-compliant.
CE marking One of the measures included in RoHS 2 to ensure more
effective policing is to include RoHS compliance as part of the CE marking requirement. As such a declaration of compliance has to be submitted by the OEM in accordance with Annex 2 of Directive 768/2008/EC – which details the requirements for CE marking. Under Annex 2 of the CE marking requirements, the technical documents should include:
An assessment of RoHS compliance and an assessment of the risk of non-compliance within:
• The design of the product for example: raw materials, plating finishes, patching materials, etc.
• And the production processes for example: • Contamination of trace chemicals during the
manufacturing processes.
• Mixing compliant and non-compliant product within the manufacturing processes.
• Mixing compliant and non-complaint product within the distribution chain.
Also where applicable, the documentation should include: • A description of the product. • A breakdown of the materials used. • An assessment of those materials. • And possibly test reports.
108 Fastener + Fixing Magazine • Issue 72 November 2011
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52 |
Page 53 |
Page 54 |
Page 55 |
Page 56 |
Page 57 |
Page 58 |
Page 59 |
Page 60 |
Page 61 |
Page 62 |
Page 63 |
Page 64 |
Page 65 |
Page 66 |
Page 67 |
Page 68 |
Page 69 |
Page 70 |
Page 71 |
Page 72 |
Page 73 |
Page 74 |
Page 75 |
Page 76 |
Page 77 |
Page 78 |
Page 79 |
Page 80 |
Page 81 |
Page 82 |
Page 83 |
Page 84 |
Page 85 |
Page 86 |
Page 87 |
Page 88 |
Page 89 |
Page 90 |
Page 91 |
Page 92 |
Page 93 |
Page 94 |
Page 95 |
Page 96 |
Page 97 |
Page 98 |
Page 99 |
Page 100 |
Page 101 |
Page 102 |
Page 103 |
Page 104 |
Page 105 |
Page 106 |
Page 107 |
Page 108 |
Page 109 |
Page 110 |
Page 111 |
Page 112 |
Page 113 |
Page 114 |
Page 115 |
Page 116 |
Page 117 |
Page 118 |
Page 119 |
Page 120 |
Page 121 |
Page 122 |
Page 123 |
Page 124 |
Page 125 |
Page 126 |
Page 127 |
Page 128 |
Page 129 |
Page 130 |
Page 131 |
Page 132 |
Page 133 |
Page 134 |
Page 135 |
Page 136 |
Page 137 |
Page 138 |
Page 139 |
Page 140 |
Page 141 |
Page 142 |
Page 143 |
Page 144 |
Page 145 |
Page 146 |
Page 147 |
Page 148 |
Page 149 |
Page 150 |
Page 151 |
Page 152 |
Page 153 |
Page 154 |
Page 155 |
Page 156