The RoHS directive specifically mentions the electrical and electronic industry and through its annex and WEEE, it excludes medical devices and other products.

If not specifically excluded in WEEE or in the RoHS annex, is RoHS aimed at other industries as well as electronics?

My understanding is that if it has anything to do with an end-product that you would classify as "electronics", then it applies.

For example, we make doming/lensing resins. Electrical/electronic? No. Used to dome a label that goes on something electrical/electronic (i.e., a phone, camera, etc.)? Maybe...if so, then we're required to follow RoHS.

Clarification of the *very* end use of your product should point you in the right direction.

Hope this helps,
-R.

I think it was said above, however yes RoHS only related to electronic products, as defined in the scope and categories given in the RoHS directive.

Strictly speaking the label mentioned above that could be applied to an electronic device is in itself a component and is not in itself electronic equipment, hence the producer of the label would not have to comply with RoHS.

The person however who applies this label to his electronic device would have to comply with the RoHS directive as he is the 'producer' of the electronic equipment and therefore responsible under the directive. He of course may start asking his label produced for information on chemical content, so although there may be no legal obligation, RoHS type declarations of chemical content may force their way down the supply chain to all sorts of things.

So, if my component goes into an electrical or electronic end product, as defined by Annex 1B in WEEE, I don't have to be concerned about RoHS and WEEE unless there's a flow down requirement from the OEM I'm selling to?

Rosie,

I can't specifically answer your question, but I can tell you my experience.

I work for a sheet metal job shop. We have 3 customers who have request RoHS information from us. One customer makes medical devices, another machine controllers and the third makes exercise equipment.

So, if my component goes into an electrical or electronic end product, as defined by Annex 1B in WEEE, I don't have to be concerned about RoHS and WEEE unless there's a flow down requirement from the OEM I'm selling to?Rosie, if you know that your customer is using your component in a product for export to the EU, according to ISO 9000 7.2.1 (b), you should be concerned. I attached the consolidated text of the ROHS directive in this post. (http://elsmar.com/Forums/showpost.php?p=107117&postcount=26) For reference, I've attached the WEEE directive, the original ROHS directive as well as a document on exemptions.

To add to the complexity - we're a manufacturer of bulk materials (iron powders & mixes/blends of metal powders with a base of iron powder to be precise) and have just received a request from a customer to confirm ROHS compliance. For the information of any not familiar with powder metallurgy applications: Our customers take the powders and mixes, compact them to a near net shape part in a press, then sinter them around 1900 F in an atmosphere furnace to produce intricately shaped parts that require minimal machining before use. About 60% of our product ends up in automotive applications.

Ao, this thread was initiated at a very appropriate time from my perspective, and I really appreciate the information provided by Al.

There are a lot of companies sending out questionnaires on RoHS and WEEE to their suppliers. Many it appears have taken a broad brush approach by asking all their suppliers, regardless of the products/materials they procure, and often have little understanding of these directives - this is understandable to a certain extent due to the growing hysteria and the fact that they have not transferred into national laws in most EU member states.

I received one the other day for a spray cleaner product we sell, and asked for a declaration of compliance to the WEEE directive !!

Beware, just because you are asked does not necessarily mean you have to comply.

Clearly however if your component in heavily used in the electronics industry, and it is loaded with harmful substances you might well find your market sharply declining. However in terms of legal obligations not to place electronic products on the market containing certain levels of banned substances, this responsibility is on the equipment producer.

Al or Mark, has there been any discussion of what constitutes "large scale industrial tools"?

We make products that go into oil drilling equipment, which would certainly qualify, but we also make product that goes into a host of different smaller machine tools. What is the dividing line for "large scale"?

Al or Mark, has there been any discussion of what constitutes "large scale industrial tools"?

We make products that go into oil drilling equipment, which would certainly qualify, but we also make product that goes into a host of different smaller machine tools. What is the dividing line for "large scale"?From what I've read, a large-scale stationary industrial tool is "a machine or system consisting of a combination of equipment, systems or products, each of which is manufactured and intended to be used only in fixed industrial applications".