The following is a rough outline of the environmental directives RoHS (Restriction of Hazardous Substances), WEEE (Waste of Electrical and Electronic Equipment) and ELV (End of Life Vehicles) and their effect on our industrial products.
1. The RoHS and WEEE directives are aimed at 10 categories of electrical and electronic equipment:
- large household appliances
- small household appliances
- IT and telecommunications equipment
- consumer equipment
- lighting equipment
- electrical and electronic tools (with the exception of large-scale stationary industrial tools)
- toys, leisure and sports equipment
- medical devices (with the exception of all implanted and infected products)
- monitoring and control instruments
- automatic dispensers
This equipment is mainly but not exclusively used privately. Components with no meaningful function of their own, such as relays and switches, are not mentioned at all.
2. The RoHS directive is applied uniformly in Europe and bans lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE) as hazardous substances from July 1, 2006 onwards.
Within the scope of this directive, categories 8 and 9 of the 10 categories listed above are explicitely excluded for the time being. This means, when our components are used in medical or industrial devices they are, strictly speaking, not covered by the RoHS directive. When used in the other categories, e.g. household appliances, then compliance is required. We assume that such details are not known in the market to the necessary extent. Hence, in practically all cases RoHS-compliant components are requested. As a consequence PEW decided to replace the hazardous substances in due time. (This is also in conformity with the environmental politics of Panasonic.) As a result of this environmental policy, all Panasonic relays are now ROHS compliant. This is also true for relays with AgCdO contacts, as there is an exemption for Cd containing contacts from the prohibition of ROHS-directive presently. So besides Cd-free relays, Panasonic will keep relays with AgCdO contacts available upon the customer's request.
3. The WEEE directive establishes minimum requirements for the handling the waste of electrical equipment which has to be accomplished country by country via national laws. The goal of the directive and the corresponding national laws is the environmentally conscious disposal of waste of electrical and electronic equipment used privately or in industry, focussing primarily on appliances and equipment (§1). The question remaining open was to which extent components of industrial controls are subject to the scope of this directive, e.g. relays, contactors, sensors, monitoring and control instruments, control instruments, control devices, PLCs, inverters or electrical drives.
According to article 2, the directive encompasses electrical and electronic equipment in the categories listed in annex 1A, provided that the equipment concerned is not part of another type of equipment that does not fall within the scope of this directive. Such equipment, namely large scale stationary industrial tools, is listed in category 6 of annex 1A and is hence explicitly excluded from the scope of the directive. According to Orgalime (Liaison Group of the European Mechanical, Electrical, Electronic and Metalworking Industries) large-scale stationary tools are:
Machines or systems consisting of a combination of equipment and/or components, each of which is manufactured to be used in industry only, permanently fixed and installed by professionals at a given place in industrial machinery or in an industrial building to perform a specific task. They are not intended to be placed on the market as a single functional or commercial unit. Equipment that is part of another type of equipment is not considered to be a finished product.
As parts of a fixed installation, e.g. industrial monitoring, controls and drive components in this respect are exempted as they are part of and form a functional unit of the machine. Hence they are not subject to the WEEE directive.
Furthermore, tool machinery or even machine systems and the related components and control units are not comparable to those of private households with respect to waste disposal at the end of their life neither with regard to their characteristics nor the quantity in which they are produced. Moreover, these goods have not been nor will be disposed of in municipal waste.
Summarizing, components of monitoring and controls technology as well as electrical drives being used in large-scale stationary industrial tools are generally not subject to the WEEE directive or the respective national laws. Hence registering our company with national registration authorities, e.g. EAR in Germany, is not necessary for these products.
We continue to observe the development of the handling of this directive and the corresponding national laws.
4. The ELV directive has the aim of preventing waste from vehicles, to reuse, to recycle and to recover end-of-life vehicles and their components. Therefore our automotive components for vehicles put on the market after July 1, 2003 shall not contain lead, mercury, cadmium or hexavalent chromium. In annex II of this directive some exceptions are mentioned, e.g. for lead 60 grams per vehicle in total are allowed. However, such details are difficult to communicate in the sales field. Similar as mentioned in connection with RoHS directive, MEW is therefore aiming to totally avoid such substances in automotive components.
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