FEATURE CE MARKING Look out for changes to the RoHS Directive
By Paul Taylor, head of industrial products (UK) at TÜV SÜD Product Service, a global product testing and certification organisation
distorting treatment of cord-connected non-road mobile machinery in comparison to otherwise identical machinery powered by a battery or an engine, the latter of which is currently excluded from RoHS scope. This means that traction-driven machinery is now captured within the scope of RoHS. This essentially means that the CE
T
he Restriction of Hazardous Substances (RoHS) Standard, was
introduced by the European Union (EU) in 2002, with all applicable products having to pass RoHS compliance since 1 July 2006. The second incarnation of RoHS came into force on 22 July 2011, with the application and enforcement aligned to the New Legislative Framework, alongside other EU directives.
HAZARDOUS SUBSTANCES RoHS’s aim is to eradicate certain hazardous substances from new electrical and electronic equipment (EEE). It therefore restricts the use of certain hazardous substances in EEE, specifying maximum levels for ten of them: • Lead • Mercury • Cadmium • Hexavalent Chromium • Polybrominated Biphenyls • Polybrominated Diphenyl Ethers • Bis(2-Ethylhexyl) phthalate • Benzyl butyl phthalate • Dibutyl phthalate • Diisobutyl phthalate The Directive requires that EEE
products must not contain more than 0.1 per cent of any of these listed substances, with cadmium being restricted to no more than 0.01 per cent. Permanent exclusions from RoHS
include military equipment, space equipment, equipment designed to be part of another piece of equipment falling outside the scope of RoHS, large scale industry tools, large scale fixed installations, transport, non-road mobile machinery, assembly equipment that is only available business-to-business (it cannot be sold to general consumers). Spare parts for electronic equipment that
S10 MAY 2018 | MACHINE SAFETY SUPPLEMENT
was on the market before 1 July 2006 is also excluded. If you are building machinery that can
only be used as part of an assembly of machines, you may not have to comply as the overall assembly does not need to comply. However, if your equipment can be used on its own or as part of an assembly, then you will have to comply.
The addition of RoHS to the machinery
compliance mix means that CE marking is becoming increasingly complex "
ROHS DIRECTIVE Until now RoHS has not been a concern for the Machinery Industry. However, from 22 July 2019 it will apply to all EEE products that are “dependent on electric current or electromagnetic fields for at least one intended function”. This means that in order to place a CE marking on it, any industrial equipment will have to comply with the RoHS Directive, just like it does with the Machinery Directive, Low Voltage Directive and the EMC Directive. Any business that sells applicable
electrical or electronic machinery, sub- assemblies, cables, components, or spare parts directly to RoHS countries, or sells via resellers, distributors or integrators, is impacted if their products contain any of the restricted substances. The European Commission has made these updates as it identified a number of issues related to the scope which needed to be addressed to avoid the legislation having unintended effects. Of particular relevance to the machinery industry is that it identified that after 22 July 2019 there would be a different, and
marking of machinery, which depends on electricity to run, must include the requirements of the RoHS Directive. Only fixed installations, such as complex assemblies of machines, will be exempted - necessitating smaller machines, which can be moved around a site with relative ease, to meet RoHS compliance requirements for the first time. Certainly smaller equipment, such as
packing machines and labellers will fall within RoHS’s scope within the next 18 months, and it will apply to every part of the machinery, including the paint and labels. While the RoHS requirements apply to end products, as a final product is made up of components and sub- assemblies, it is imperative that these do not contain any of the restricted substances above, in the defined maximum concentration values. The technical file must also contain the
analysis and component data, and be kept for at least four years from the date that the equipment was put on the market. If an exemption is claimed, this must be clearly justified within the technical file.
ALL CHANGE From July 2019, as part of the CE marking process, machinery manufacturers will be required to design and manufacture EEE in compliance with RoHS, produce the required technical documentation and a declaration of conformity. The addition of RoHS to the machinery
compliance mix means that CE marking is becoming increasingly complex. It is therefore advised that machinery builders and owners seek expert guidance if they are wondering whether an exclusion or exemption applies to their products.
TÜV SÜD Product Service T: 01489 558100
www.tuv-sud.co.uk
/AUTOMATION
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