Updates: RoHS Around the World

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Updates: RoHS Around the World

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Updates: RoHS Around the World




Today’s Presenter

3

Valerie KuntzAssent ComplianceSubject Matter Expert

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Introduction




Assent Product SuitesOur Market Leading Platform

Corporate Social Responsibility Product Compliance

Vendor Management Inspections




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Feature Presentation



[email protected] / www.assentcompliance.com / 1 866 964 6931 / © Assent Compliance 2017

Concern for the health of citizens and the environment leads to implementation of directives and regulations in countries around the world.

Some examples:■ EU RoHS■ China RoHS■ UAE RoHS■ Customs Union (EAEU) RoHS

RoHS in the World

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Regulation: 2011/65/EU RoHS 2

Substances & Threshold:■ Cadmium (Cd) and its compounds: 0.01 percent■ Mercury (Hg) and its compounds: 0.1 percent■ Lead (Pb) and its compounds: 0.1 percent■ Hexavalent chromium (Cr6+) and its compounds: 0.1 percent■ Polybrominated biphenyls (PBB): 0.1 percent■ Polybrominated diphenyl ethers (PBDE): 0.1 percent

Included after July 22, 2019, per Directive (EU) 2015/863:■ Bis(2-Ethylhexyl) phthalate (DEHP): Max 0.1 percent■ Benzyl butyl phthalate (BBP): Max 0.1 percent■ Dibutyl phthalate (DBP): Max 0.1 percent■ Diisobutyl phthalate (DIBP): Max 0.1 percent

Effective Date: January 2, 2013

EU RoHS 2

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Exemption Extension Update

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Recommendations from Oeko and Fraunhofer IZM:■ All requests for extensions were recommended for approval, but

some were only applicable to Categories 8 and 9, as well as Category 8 in vitro and Category 9 industrial

■ Eleven new exemptions under evaluation

European Commission Actions:■ Three exemption extensions have been approved by the European

Commission: 9(b), 13(a) and 13(b); four new exemptions have been implemented and go into effect July 6, 2018

■ Eight exemption extensions have been proposed by the European Commission: 6(a), 6(b), 6(c), 7(a), 7(c)-I, 18(b), 24, and 34




EX # EXEMPTION TEXT EXPIRATION

9(b) – oldLead in bearing shells and bushes for refrigerant- containing compressors for heating, ventilation, air conditioning and refrigeration (HVACR) applications

6 July 2018

9(b)Lead in bearing shells and bushes for refrigerant containing compressors for heating, ventilation, air conditioning and refrigeration (HVACR) applications

21 July 2021 (Cat 8 and 9) 21 July 2023 (Cat 8 in vitro)

21 July 2024 (Cat 9 indust and 11)

9(b)-(I)

Lead in bearing shells and bushes for refrigerant containing hermetic scroll compressors with a stated electrical power input equal or below 9 kW for heating, ventilation, air conditioning and refrigeration (HVACR) applications

21 July 2019 (Cat 1)

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Renewed Exemptions





13(a) – old Lead in white glasses used for optical applications 6 July 2018

13(a) Lead in white glasses used for optical applications

21 July 2021 (All)

21 July 2023(Cat 8 in vitro)


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Renewed Exemptions





13(b) – old Cadmium and lead in filter glasses and glasses used for reflectance standards 6 July 2018

13(b) Cadmium and lead in filter glasses and glasses used for reflectance standards



13(b)-(I) Lead in ion colored optical filter glass types 21 July 2021 (Cat 1 to 7 and 10)

13(b)-(II)Cadmium in striking optical filter glass types; excluding applications falling under point 39 of thisAnnex

21 July 2021 (Cat 1 to 7 and 10)

13(b)-(III) Cadmium and lead in glazes used for reflectance standards 21 July 2021 (Cat 1 to 7 and 10)

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Renewed Exemptions




Exemptions Under ReviewEX # EXEMPTION TEXT EXPIRATION

6(a) – oldLead as an alloying element in steel for machining purposes and in galvanized steel containing up to 0.35 percent lead by weight

TBD

6(a)Lead as an alloying element in steel for machining purposes and in galvanized steel containing up to 0.35 percent lead by weight



6(a)-(I)

Lead as an alloying element in steel for machining purposes containing up to 0.35 percent lead by weight and in batch hot dip galvanized steel components containing up to 0.2 percent lead by weight

21 July 2021 (Cat 1 to 7 and 10)

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6(b) – oldLead as an alloying element in aluminium containing up to 0.4 percent lead by weight TBD

6(b)Lead as an alloying element in aluminium containing up to 0.4 percent lead by weight



6(b)-ILead as an alloying element in aluminium containing up to 0.4 percent lead by weight, provided it stems from lead-bearing aluminium scrap recycling

21 July 2021 (Cat 1 to 7 and 10)

6(b)-IILead as an alloying element in aluminium for machining purposes with a lead content up to 0.4 percent by weight

3 years after publishing (Cat 1 to 7 and 10)

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Exemptions Under Review





7(a) – oldLead in high melting temperature type solders (i.e. lead-based alloys containing 85 percent by weight or more lead) TBD

7(a)Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 percent by weight or more lead)

21 July 2021 (Cat 1 to 7 and 10, except point 24 of this Annex)

21 July 2021 (Cat 8 and 9)21 July 2023 (Cat 8 in vitro)


7(c)-I – old

Electrical and electronic components containing lead in a glass or ceramic other than dielectric ceramic in capacitors, e.g. piezoelectronic devices, or in a glass or ceramic matrix compound

TBD

7(c)-I

Electrical and electronic components containing lead in a glass or ceramic other than dielectric ceramic in capacitors, e.g. piezoelectronic devices, or in a glass or ceramic matrix compound

21 July 2021 (Cat 1 to 7, 8 to 10)21 July 2023 (Cat 8 in vitro)


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18(b) – old

Lead as activator in the fluorescent powder (1 percent lead by weight or less) of discharge lamps when used as sun tanning lamps containing phosphors such as BSP (BaSi2O5:Pb)

TBD

18(b)

Lead as activator in the fluorescent powder (1 percent lead by weight or less) of discharge lamps when used as sun tanning lamps containing phosphors such as BSP (BaSi 2 O 5 :Pb)



18(b)-I

Lead as activator in the fluorescent powder (1 percent lead by weight or less) of discharge lamps containing phosphors such as BSP (BaSi2O5:Pb), when used in tanning equipment or in medical phototherapy equipment - excluding applications covered under point 34 of Annex IV

21 July 2021 (Cat 5)

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24 – oldLead in solders for the soldering to machined through hole discoidal and planar array ceramic multilayer capacitors

TBD

24Lead in solders for the soldering to machined through hole discoidal and planar array ceramic multilayer capacitors



34 – old Lead in cermet-based trimmer potentiometer elements TBD

34 Lead in cermet-based trimmer potentiometer elements



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New Exemption Requests

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Request 2017-1 “Lead in solder used to make electrical connections to vacuum boards used in mass spectrometers. Boards designed to be used periodically under low pressure. 5 years.”Request 2017-2 “Use of lead in welds for soldering of certain printed circuit board assemblies in gas detectors."Request 2017- 3 "Lead in solders of alpha spectrometers, pulse-processing electronics, scintillation detectors and spectroscopy systems used in equipment to identify radiation, expiring on 23 July 2024."Request 2017- 4 “Lead in solder and hexavalent chromium in parts used to make RF detectors in mass spectrometers, to be added to Annex IV.”Request 2017- 5 "Lead in thermal cut-off fuses overmolded into solenoid coils used in industrial monitoring and control instruments (Category 9) and EEE falling under Category 11."Request 2017- 6 "Bis (2-ethylhexyl) phthalate in rubber parts such as O-rings, seals, vibration dampers, gaskets, hoses, grommets and cap-plugs that are used in engine systems including exhausts and turbochargers that are designed for use in equipment that is not designed solely for consumer use."Request 2017- 7 "Lead in solders of sensors, actuators and engine control units (ECUs) that are used to monitor and control engine systems including turbochargers and exhaust emission controls of internal combustion engines used in equipment that are not intended to be used solely by consumers."



http://rohs.exemptions.oeko.info/index.php?id=276








New Exemption Extension Requests

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Expiring December 31, 2018:

Annex III, 1(g) “Mercury in single – capped (compact) fluorescent lamps for general lighting purposes < 30 W with a lifetime equal or above 20,000 h: 3.5 mg. 5 years (Max).”

Annex III, Ex. 41 “Lead in solders and termination finishes of electrical and electronic components and finishes of printed circuit boards used in ignition modules and other electrical and electronic engine control systems, which for technical reasons must be mounted directly on or in the crankcase or cylinder of hand-held combustion engines (classes SH:1, SH:2, SH:3 of Directive 97/68/EC of the European Parliament and of the Council ( 2 )).”






New Exemption Extension Requests

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Expiring December 31, 2018:

Annex IV, Ex. 37 "Lead in platinized platinum electrodes used for conductivity measurements where at least one of the following conditions applies:

a) wide-range measurements with a conductivity range covering more than one order of magnitude (e.g. range between 0.1 mS/m and 5 mS/m) in laboratory applications for unknown concentrations;

b) measurements of solutions where an accuracy of +/– 1 % of the sample range and where high corrosion resistance of the electrode are required for any of the following:i) solutions with an acidity < pH 1;

ii) solutions with an alkalinity > pH 13;iii) corrosive solutions containing halogen gas;

c) measurements of conductivities above 100 mS/m that must be performed with portable instruments.”

Annex IV, Ex. 41 “Lead as a thermal stabilizer in polyvinyl chloride (PVC) used as base material in amperometric, potentiometric and conductometric electrochemical sensors which are used in in-vitro diagnostic medical devices for the analysis of blood and other body fluids and body gases."






1. Adding pipe organs as a permanently excluded item.

2. Allowing NRMM with the power source either on board or external.

3. Allowing use of non-compliant spare parts and cables for the repair, reuse and

updating of Category 11 products placed on the market before July 22, 2019.

4. Adding extended placed-on-market dates for reused spare parts for Category 8

(normal and in vitro); Category 9 (normal and industrial); and Category 11.

5. Updating exemption validity paragraph:

a. For categories 1 to 7 and 10: expire five years from July 21, 2011;

b. For categories 8 and 9: expire seven years from their implementation dates;

c. For category 11: expire five years from July 22, 2019.

6. Changing timeframe for decision on exemption extensions.

Additional Proposed Changes




Regulation: Management Methods for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products

New Regulation: SJ/T 11364-2014

Old Regulation: SJ/T 11364-2006

Date Legislation Signed: January 6, 2016

Effective Date: July 1, 2016

China RoHS 2

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■ Cadmium (Cd) and its compounds: 0.01 percent■ Mercury (Hg) and its compounds: 0.1 percent■ Lead (Pb) and its compounds: 0.1 percent■ Hexavalent chromium (Cr6+) and its compounds: 0.1

percent■ Polybrominated biphenyls (PBB): 0.1 percent■ Polybrominated diphenyl ethers (PBDE): 0.1 percent

Substances & Threshold




China RoHS 2 Included Products:Electrical and Electronic Products (EEP) = Equipment dependent on electric current or electromagnetic fields for operation, and equipment used for the generation, transfer and measurement of such currents and fields, with a working voltage rating not to exceed 1,000 volts alternating current or 1,500 volts direct current.

Products “placed on the market" are in scope.

■ Spare or accessory products sold separately without an intended end product are considered standalone and must meet the requirements of a full product

■ Full product replacement is considered a new product and must meet the compliance requirement of that date

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China RoHS 2 Excluded Products:

■ Equipment related to electric energy production, transmission and distribution, such as systems and devices used for power stations, power distribution stations and building power supply and distribution

■ Electrical and electronic equipment used for military purposes■ Electrical and electronic equipment used in a special or extreme environment■ Electrical and electronic equipment used for export

Note: Electrical and electronic equipment used for export shall comply with provisions related to restricted use of hazardous substances in the country/region of ultimate destination

■ Electrical and electronic equipment that are temporarily imported, or imported for repair, but not for sale

■ Prototypes used for scientific research/research and development, and testing■ Samples and exhibits used for exhibition and display, but not for sale

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Draft of first catalog requiring restriction of substances released June 29, 2017. Implementation date not defined.

Impacts:■ Air conditioners■ Electric water heaters■ Fax machines■ Microcomputers■ Mobile communication devices■ Photocopiers■ Printers■ Refrigerators■ Telephones■ Televisions■ Monitors■ Washing machines

China RoHS 2 Updates




57 Exemptions Included:

China RoHS 2 Updates Exemptions

SUBSTANCE COUNT OF EXEMPTIONS

Mercury 12

Lead 36

Lead and Cadmium 2

Cadmium 6

Chromium VI 1




China RoHS 2 - Exemption Example




China RoHS 2 - Compliance Remaining Scope

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■ Label on the product indicating compliance (e-logo) or non-compliance (EFUP)■ Hazardous substance table with all parts contained within the product, or individual

tables for each part■ Manufacture date on product■ Conformity assessment (replacing in-country testing)




China RoHS 2 - Showing Compliance - Labeling

CONDITION LABEL

None of the six substances exist in the product above threshold.

Product contains one or more of the six substances above threshold. Number indicates the minimum number of safe years.

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China RoHS 2 - Hazardous Substance TableThe following hazardous substance disclosure table applies to <manufacturer name>, <manufacturer part name/number> which <is/is not> China RoHS Compliant.

Table of Hazardous Substances Name & Concentration

Part Name

Hazardous Substances

Lead(Pb)

Mercury(Hg)

Cadmium(Cd)

Hexavalent Chromium(Cr(VI))

Polybrominated biphenyls

(PBB)

Polybrominated diphenyl ethers

(PBDE)

Mounting Substrate X O O O O O

Cabinet O O X O O X

Cathode-ray tube X O O O O O

This table is prepared in accordance with the provisions of SJ/T 11364.O: Indicates that said hazardous substance contained in all of the homogeneous materials for this part is below the limit requirement of GB/T 26572.X: Indicates that said hazardous substance contained in at least one of the homogeneous materials used for this part is above the limit requirement of GB/T 26572.Enterprises may provide in this box a further technical explanation for marking “X” based on their actual circumstances.

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United Arab Emirates (UAE) RoHSRegulation: UAE Resolution on the System to Restrict the Rates of Hazardous Materials in Electronic Devices

Substances & Threshold:

■ Cadmium (Cd) and its compounds: 0.01 percent■ Mercury (Hg) and its compounds: 0.1 percent■ Lead (Pb) and its compounds: 0.1 percent■ Hexavalent chromium (Cr6+) and its compounds: 0.1 percent■ Polybrominated biphenyls (PBB): 0.1 percent■ Polybrominated diphenyl ethers (PBDE): 0.1 percent

From Jan 1, 2020 (Categories 1 to 7, 10 and 11); Jan 1, 2022 (Categories 8 and 9):

■ Bis(2-Ethylhexyl) phthalate (DEHP): Max 0.1 percent■ Benzyl butyl phthalate (BBP): Max 0.1 percent■ Dibutyl phthalate (DBP): Max 0.1 percent■ Diisobutyl phthalate (DIBP): Max 0.1 percent

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Effective Date: Scheduled for January 1, 2018




Effective Date: January 1, 2020

■ Medical devices

■ In vitro diagnostic medical devices

■ Monitoring and control instruments

■ Industrial monitoring and control instruments

United Arab Emirates (UAE) RoHS

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Included Products:

1. Large household appliances2. Small household appliances 3. IT and telecommunications equipment4. Consumer equipment 5. Lighting equipment6. Electrical and electronic tools (with the exception of large-scale stationary industrial tools) 7. Toys, leisure and sports equipment

10. Automatic dispensers11. Other EEE not covered by any of the categories above

All products, including cables and spare parts for their repair, their reuse, updating of their functionalities or upgrading of their capacity

After January 1, 2020:

8. Medical devices (with the exception of all implanted and infected products)9. Monitoring and control instruments, including industrial monitoring and control instruments


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Excluded Products:

■ Products for security of the country, including arms, munitions and war material intended for specifically military purposes

■ Products designed to be sent into space■ Equipment designed to be part of non-scope equipment■ Large-scale stationary industrial tools■ Large-scale fixed installations■ Means of transport for persons or goods, excluding electric two-wheel vehicles that are not

type-approved■ Non-road mobile machinery made available exclusively for professional use■ Active implantable medical devices■ Photovoltaic panels intended to be used in a system that is designed, assembled and installed by

professionals for permanent use at a defined location to produce energy from solar light for public, commercial, industrial and residential applications

■ R&D equipment and only made available on a business-to-business basis


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Exemptions: Yes, similar to EU RoHS

How to show compliance: Option 1:

■ Risk assessment to be submitted in case the full product assessment for RoHS is not completed.

■ Applicant submits a full RoHS test report of the complete product (if available). Otherwise, three test reports of the critical component must be submitted.

■ How one determines what is “critical” is unclear.■ ESMA will verify compliance and issue the certificate.■ Only valid for one year; annual renewal (and, probably, retest) is required.


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How to show compliance: Option 2:

■ Similar to the EU risk-based approach, the applicant submits risk assessment documents based on IEC 63000 (the approved international standard equivalent to EN 50581:2012, the EU’s RoHS risk assessment harmonized standard for RoHS) and IEC 62476:2010, “Guidance for evaluation of product with respect to substance-use restrictions in electrical and electronic products.” This is a standard few are familiar with or use.

■ ESMA – or their agents – verifies compliance with requirements and issues the certificate.■ Must place Emirates Quality Mark (EQM) on product (yes, another mark).■ Valid for three years.


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Eurasian Customs Union RoHS

Eurasian Customs Union/Eurasian Economic Union (EAEU) Countries: The Russian Federation, and the Republics of Kazakhstan, Belarus, Armenia and Kyrgyzstan

Regulation: Technical Regulations “On Restriction of Hazardous Substances in Electrical and Electronic Equipment”

Substances & Threshold:

■ Cadmium (Cd) and its compounds: 0.01 percent■ Mercury (Hg) and its compounds: 0.1 percent■ Lead (Pb) and its compounds : 0.1 percent■ Hexavalent chromium (Cr6+) and its compounds: 0.1 percent■ Polybrominated biphenyls (PBB): 0.1 percent■ Polybrominated diphenyl ethers (PBDE): 0.1 percent

Effective Date: Transition starts March 1, 2018 ends March 1, 2020

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Included Products:

1. Electrical apparatuses and appliances for household use2. Electronic computers and their peripherals (connected to them)3. Telecommunication (terminal telecommunication) equipment4. Copiers and other electrical office equipment5. Electrical tools (manual and portable electric machines)6. Sources of light and lighting equipment, including equipment built into furniture7. Electrical music tools8. Vending machines and gaming machines9. Cash registers, ticket printers, ID card readers, information kiosks, ATMs, card terminals

10. Cables, wires and cords intended for use at a rated voltage below 500 V AC/DC, except for fibre optic cables

11. Automatic switches and residual current devices12. Fire, security and fire-security alarms/detectors




Excluded Products:

1. Products designed for use at nominal voltage exceeding 1000 V AC or 1500 V DC unless otherwise provided in Annex 1

2. Products designed solely for use as components of electrical and electronic equipment that are not listed in Annex 1

3. Electric toys4. Photovoltaic panels/solar panels used as part of the electrical and electronic equipment 5. Products designed to be used in land-based and orbiting space objects6. Products intended solely for the use of air, water, ground and underground transport7. Batteries and accumulators, including those put into circulation on the territory of the CU as part of

electrical products8. Used electrical and electronic equipment9. Measuring instruments

10. Medical devices





Exemptions: Similar to EU ROHS Annex III exemptions

How to show compliance:

EEE products must be labeled with the following information:

■ Name and/or product designation and type, make and model (if any)■ Main parameters and characteristics■ The name and/or trademark of the manufacturer■ The name of the state in which the product is made (either on the product or specified in the

attached operational documents).

If the information above cannot be applied to the product, it can be specified in the accompanying documentation.

All labeling should be in the language of the member country receiving the product


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How to show compliance (cont):

Option 1: EEE are subject to the confirmation of compliance in the form of the declaration of conformity by one of the following schemes:

■ For products manufactured serially - schemes 1d, 3d and 6d■ For a batch of products (a consignment) - schemes 2d and 4d.

Option 2: The conformity assessment of EEE by the declaration of conformity may be replaced by certification and according to one of the following schemes:

■ For products manufactured serially - schemes 1c, 2c and 6c■ For a batch of products (a consignment) – scheme 3c.





■ By their own declaration that the product complies with the provisions of the technical regulation (i.e. that the testing required to ensure conformity was conducted); or

■ By referring to certification from an accredited laboratory proving the products comply with the provisions of the regulation.

■ All products will still be required to be labeled with the correct CU conformity mark.


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■ EU RoHS has many exemptions that are under consideration.

■ EU RoHS has some changes to the directive that could have significant impact on certain industries.

■ China RoHS draft catalog released, could be in scope soon.

■ UAE RoHS is coming into scope Jan 1st. Need to be ready!

■ EAEU (Customs Union) RoHS will begin the transition Mar 1, 2019; and goes into effect Mar 1, 2020.

■ Most of the RoHS regulations are similar to the EU RoHS, but have minor differences.

Summary



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Questions/DiscussionConclusion







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Back Up




Declaration d-Scheme common items:■ Elaboration and analysis of technical documentation■ Acceptance and registration of declaration of conformity■ Application of a common circulation mark

Declaration Scheme 1d includes:◆ Implementation or production control◆ Testing of product samplesDeclaration Scheme 2d, 3d, and 4d includes:◆ Testing of product batch (single unit)Declaration Scheme 6d includes:◆ Development and analysis of the technical documentation which, on a mandatory

basis, includes the management systems certificate◆ Implementation of production control◆ Testing of product samples◆ Control over the stability of the management system functions





Certification Scheme 1c includes:■ Applicant submits application to product certification body to conduct certification with■ accompanying technical documentation■ Product certification body examines the application and makes decision on it■ Product certification body summarizes the results of testing and analysis of production

condition and issues a certificate of conformity to the Applicant■ Application of a single circulation sign■ Inspection control over the certified products

Certification Scheme 2c:■ Applicant submits application to product certification body for conducting certification with■ accompanying technical documentation which, on a mandatory basis, shall include the

management systems certificate(copy of certificate)■ Certification body examines the application; testing laboratory conducts sample testing■ The results are summarized and, if satisfied, certificate of conformity is issued■ Application of a single circulation sign■ Inspection control over certified products and control over stability of the management

system operation





Certification Scheme 3c:■ Applicant submits application to product certification body for conducting certification with■ accompanying technical documentation■ Examination of application and making decision by the certification body on certification of

products■ Certification body selects product samples for testing■ Accredited testing laboratory conducts sample testing■ Product certification body analyses the test results and issues certificate of conformity to

Applicant■ Common circulation mark is applied to product batches

Certification Scheme 6c:■ Applicant submits application to product certification body for conducting certification with■ accompanying technical documentation which, on a mandatory basis, shall include the

management systems certificate (copy of certificate)■ Certification body conducts examination of product■ Product certification body summarizes the results of analysis and issues certificate of conformity■ Common circulation mark is applied■ Inspection control over the certified products (control over stability of management system■ functions)




Updates: RoHS Around the World

Education

Transcript of Updates: RoHS Around the World