Hazardous substances (lead) in toys & sports equipment

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Lester
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Hazardous substances (lead) in toys & sports equipment

Post by Lester » 28 Oct 2006, 06:23

There is some concern that lead is soon to be banned in the EU under RoHS and WEEE directives. I've had a look at these, and summarise the main points here. My (unofficial!) guess is that the IOM, and radio sailing, is unaffected with regard to lead in bulbs. What *is* affected is the radio gear.
DIRECTIVE 2002/95/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 January 2003 on the restriction of the use of certain hazardous substances in electrical and electronic equipment wrote: http://europa.eu.int/eur-lex/pri/en/oj/ ... 190023.pdf

Member States shall ensure that, from 1 July 2006, new electrical and electronic equipment put on the market does not contain lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE). National measures restricting or prohibiting the use of these substances in electrical and electronic equipment which were adopted in line with Community legislation before the adoption of this Directive may be maintained until 1 July 2006.
EUROPEAN COMMISSION DIRECTORATE-GENERAL ENVIRONMENT The Director-General Frequently Asked Questions on Directive 2002/95/EC on the Restriction of the Use of certain Hazardous Substances in Electrical and Electronic Equipment (RoHS) and Directive 2002/96/EC on Waste Electrical and Electronic Equipment (WEEE) wrote: http://ec.europa.eu/environment/waste/pdf/faq_weee.pdf

The opinion of the Commission is that excluded from the scope of the RoHS Directive is the equipment which part of another type of equipment that does not fall within the scope of this Directive. Therefore, equipment that is specifically designed to be installed in airplanes, boats and other means of transport (including satellites) is considered to fall outside the scope of the RoHS Directive.
DTI RoHS REGULATIONS Government Guidance Notes June 2006 wrote: http://www.rohs.gov.uk/Docs/Links/RoHS% ... 202006.pdf

[Exempt are:]
ii. Products where electricity is not the main power source. Many products contain electrical and electronic components, either for additional functionality or as peripheral parts. A simple example could be a combustion engine with an electronic ignition. The definition of EEE in the Regulations extends only to those products that are dependent on electric currents or electromagnetic fields to work properly, meaning that it is the primary power source. When the electric current is switched off, the product cannot fulfil its main function. If electricity is used only for control or support functions, the product could be considered to be outside the scope of these Regulations. In the above example the combustion engine would be considered to be outside that scope.

iii. Products where the electrical or electronic components are not needed to fulfil the primary function. This is related to, but not always the same as the above situation. Some products, particularly toys and novelty items contain an electrical or electronic element that gives added value to the product. Often there are similar products on the market fulfilling the same function, but without these components. Examples might include musical greetings cards or soft toys with electronic components, which still fulfil their primary function without their electronic components and could be considered to be outside the scope of these Regulations.

iv. Electrical and electronic equipment that is part of another type of equipment. The WEEE Directive excludes EEE that is part of another type of equipment that does not fall within the scope of the Directive. On the basis that EEE under RoHS is defined in identical terms, it is the view of the Department and the Commission’s Legal Services that such an exclusion extends to EEE under the RoHS Directive and, consequently, to the RoHS Regulations. Examples of such equipment would be lighting or entertainment equipment for use in vehicles, trains or aircraft. This type of equipment would be excluded as it is designed to be part of a product that falls outside the scope of the Directive. Equipment that is part of another type of equipment or system is considered to be outside the scope of the Directive where it does not have a direct function outside the other item of equipment or system and that other item of equipment or system is itself outside the scope of the Directive.
Lester Gilbert
http://www.onemetre.net/

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