The Impact of RoHS CE Mark on Manufacturing

It is looking likely that RoHS will become a "CE Mark Directive" over the next couple of years. This could have a massive, resource sapping, impact on manufacturers, importers and distributors, regardless of size.

Here we look at, in particular, how it will impact the manufacturer. As a caveat to the following where optoelectronic and display modules are used as types of components and are sold to be used as components in other products, it is not yet clear what action will be needed as this is not yet defined. As they are not finished products it is possible that they may not need to be CE marked. The European Commission's (EC) proposals will make RoHS a CE mark Directive and so any products in scope of RoHS must be CE marked to demonstrate that they comply.

Most displays such as TV's and monitors are already CE marked to show that they comply with both the EMC and Low Voltage Directives (LVD). Going-forward, CE marking will indicate compliance with EMC, LVD and RoHS. Manufacturers already compile technical files for EMC and LVD and will need to include RoHS compliance information as well. Also, the DoC or declaration of conformity will include RoHS in the list of applicable directives. There will be only one DoC and one technical file per product as at present but in future these will also include RoHS. Currently manufacturers have to compile documentation to show RoHS compliance and may need to show this to State enforcement authorities. However, at present there is no standard format or procedure for this.

When RoHS becomes a CE mark directive, the EC will ask CENELEC (the European Committee for Electrotechnical Standardisation) to produce harmonised standards so that in order for manufacturers to demonstrate compliance they simply need to, in theory, follow the standard. However, it is likely that the CE requirement will come into force before these standards are published. The CE mark directive will not enter into force until the RoHS recast is complete and transposed into national legislation which could well be 2013 / 2014.

Article 7 of the proposals, published in December 2009, state that manufacturers must: Ensure Electrical and Electronic Equipment (EEE) has been designed and manufactured in line with the requirements of the RoHS Directive Draw up documents and carry out the internal production controls as required. Draw up the DoC and affix the CE mark Retain technical documents and the DoC for 10 years after the EEE has been placed on the market Ensure procedures are in place for series production to remain in conformity Carry out sample testing where there is deemed to be a risk and keep a register of complaints, non-conforming EEE and product recalls Ensure that EEE, or its packaging if the size or nature of the EEE does not allow it, has identifying marking including manufacturer name and a single point contact address If a manufacturer places non-conforming EEE on the market they must take immediate corrective measures and either withdraw it or recall it.

Where EEE presents a risk the manufacturer must inform the national enforcement authority and take corrective action When requested by the enforcement authority the manufacturer must provide it with all the necessary information to demonstrate the conformity of the EEE.p the technical Manufacturers will need to re-visit their own production processes and those of any sub-contractors so they can confidently provide the confirmatory declarations and apply the CE mark to their products and importers and distributors will have to check what manufacturers have done.

Yes, this will have a huge impact on industry!

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