Service helps SMEs understand RoHS and WEEE

Following four years of successfully delivering comprehensive RoHS WEEE impact assessments, Dionics has developed a complementary new service called Scope Validator.

The RoHS Directive has presented the electronics industry with many high level technical challenges over recent years, including many complex process related issues.

However, one of the most basic tasks that still eludes many SMEs or niche producers has been that of simply classifying their equipment.

Does it fall within the scope of the legislation, and if so, where? Until this fundamental question has been answered, producers can't even begin to explore a compliance strategy.

Following four years of successfully delivering comprehensive RoHS WEEE impact assessments, Dionics has listened carefully to thousands of smaller OEMs and developed a complementary new service called "Scope Validator".

Paul Chinery, Managing Director, commented: "Since the enforcement of RoHS this summer, it has become increasingly apparent to our consultants that many smaller and medium sized manufacturers are wrongly categorising themselves with regard to RoHS (2002/95/EC) and WEEE (2002/96/EC) Directives".

"In smaller organisations, without the manpower or budget to provide full time legislative expertise, it is often left to nonspecialist purchasing or quality functions to determine whether a product falls within the scope of RoHS, WEEE or both directives".

"This decision making process can be complex when one considers the ambiguous nature of the legislation, especially where specialist nonconsumer equipment is concerned".

"Moreover, it is quite common for senior management to influence any internal evaluation, mindful of additional costs that may need to be incurred".

However, incorrect assessment could have serious implications on producers, if they are relying on inaccurate or an incomplete assessment of their equipment: Often, companies will claim an exemption that simply doesn't apply to their products, typically in the form of a "fixed installation" or a nonexclusive military application.

Other organisations have adopted exempt WEEE category 9 classification, where the inclusive category 3 more accurately reflects the products principal function (and vice versa).

It is not uncommon for some producers to be feverishly working towards compliance when they simply don't need to, as a partial, less obvious, exemption will remove any remaining source of nonconformity.

There is a common misinterpretation that network and telecommunications infrastructure equipment are exempt from both RoHS and WEEE Directives.

Although an exemption exists for lead (Pb) in the solder (RoHS 5/6), they must comply in all other respects with the legislation.

In response to this, and other common misinterpretation, Scope Validator has very clear and simple objectives: to accurately define precisely which WEEE category a product fits within (revealing whether they fall within the scope of the RoHS Directive) using all available evidence and guidance from the EU Commission, governments and industry bodies, Commission Decisions and allied community legislation; to assess if any legitimate exemptions apply, and provide the evidence necessary to support their application; and to provide a clear and legislatively accurate declaration of conformity, specific to products and their applications.

"If a company has yet to define precisely where, if at all, their products fall within the scope of RoHS and WEEE Directives, or they simply need a second opinion from independent experts to validate their legislative arguments and positioning, RoHS Validator can provide a immediate piece of mind", said Chinery.

The service is available to all international organisations and is performed by senior consultants who have been providing complex RoHS and WEEE interpretation to thousands of international blue chip organisations since 2002.

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