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RoHS Enforcement

RoHS Enforcement. Proposed Guidance Document for EU Member State Enforcement Bodies. Background. RoHS Directive - based on Article 95 Does not say how Member States or industry might comply with its requirements UK study (for the TAC) on enforcement - published April 2004

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RoHS Enforcement

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  1. RoHS Enforcement Proposed Guidance Document for EU Member State Enforcement Bodies

  2. Background • RoHS Directive - based on Article 95 • Does not say how Member States or industry might comply with its requirements • UK study (for the TAC) on enforcement - published April 2004 • TAC Workshop on MCVs – July 2004 • Member State & Industry Workshop – May 2005

  3. Guidance – Key Issues • Principles to support RoHS enforcement • Documentation that ‘producers’ should keep • How enforcement bodies might use such documentation to check for RoHS compliance • How sample preparation and analytical testing could be employed

  4. Guidance – Contents • Introduction: Aims, Objectives, Principles & the Enforcement Process • RoHS Compliance Documentation • Sample & Testing Issues

  5. Discussion Subjects - I Table One: Documentation first, then Analysis • Evidence of compliance should – in the first instance - be based on documentation, not analysis. Is that clear? • Analysis is seen as a last resort. Should Section 3 be amended to make it clear? Table Two: Compliance Flowchart • (On p. 5). Is it clear and how could it be improved?

  6. Discussion Subjects - II Table Three: Standards & Confidentiality • The IEC standard is referenced at a couple of points within the guidance, (p. 8 & 9). How do we make it clear that this standard is not mandatory? • Confidentiality issues. How do we deal with those? Table Four: Weight Threshold (proposed limit) • The 100mg figure for homogenising materials should be employed only when nothing else is possible. Not a loophole. • Would a flowchart help?

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