Rohs And Weee Directives

[UltraHighResolution]

Hi guys

I have just discovered that a large number of our Far East DVRs are not going to be RoHS or WEEE compliant. This basically means that I can get fined for selling them to you and you can get fined for selling them to the End User.

Having researched this for most of the morning I would say that DVRs clearly fall under the banner of 'Control and Monitoring equipment' which provides them with exemption from RoHS. I would also say that a CCTV system is a fixed installation, i.e. it becomes a part of the fabric of a building providing exemption from WEEE.

My questions are the following

Any other manufacturers / importers on here going through the same thing, what conclusions have you drawn?

Any installers here asked to uninstall move and reinstall CCTV systems when a company moves? I think this is rare but I may be wrong. This would form the strong basis of a legal argument regarding the WEEE exemption.

Any help would be much appreciated

Robin

[Drew]

The fixed installation argument would be hard to make for the DVR, but would be true for most CCTV cameras.

Intruder systems are fixed installations but are not exempt. When is a CCTV system not part of an intruder system? Common sense says most of the time, but what has that got to do with RoHS?

Access control systems are in the opinion of National Weights & Measure Laboratory (NWML) which is the Executive Agency of the Department of Trade & Industry tasked with enforcement exempt because they are fixed systems.

"We consider these electric door locks and systems to be 'fixed installations' and excluded from RoHS. But the entry cards if RFID type and PCs joined to the system, are not part of the fabric of the building and therefore would fall within scope of RoHS regulations"

then, at the foot of this statement:

"The advice contained in this e-mail is based on the best and most up to date information available to us at the time. However, it is not a definitive opinion as only the courts can interpret legislation with any authority."

In other words, some more legislation has come into force that isn't clear, and will bite you where it hurts if you guess wrongly. We have decided to comply in case and also because components we had in older designs containing the banned substances will become obsolete, so we won't be able to make them anyway.

And, by the way, it's been suggested that the regulations cause more harm to the environment than would have been the case if the billions spent in fiddling and tampering had not occured. Click here for an interesting Telegraph article.

[esp-protocol]

Just bloody typical....

And typically, no one in the EU is accountable.

[Drew]

This basically means that I can get fined for selling them to you and you can get fined for selling them to the End User.

I think that the manufacturer or the company importing them onto the EU market are affected. Others in the supply chain, like the installer, are not. The following copied from http://www.rohs.gov.uk implies it:

What is RoHS?

The RoHS Directive stands for "the restriction of the use of certain hazardous substances in electrical and electronic equipment". This Directive bans the placing on the EU market of new electrical and electronic equipment containing more than agreed levels of lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyl (PBB) and polybrominated diphenyl ether (PBDE) flame retardants.

Manufacturers need to understand the requirements of the RoHS Directive to ensure that their products, and their components, comply.

Here is another quote from the RoHS website:

Lifts, electric doors and gates etc are fixed installations, fitted kitchen appliances, large fixed equipment, cctv camera systems are not. Click here for the full quote

[UltraHighResolution]

Hmmm yes I saw all that but also several articles that confirmed my 'thoughts on exemption'. There is an interesting article here (http://www.pb-free.info/our_mission.htm) based on a CCTV manufacturer model which carries on to say that 80% of all electronic product can meet one of the exemption clauses - (http://www.pb-free.info/rohsexemptions.htm) - if you carry on down the page you will see Proposed exemptions 'awaiting formal review' which include Fire and Security equipment. Having said that they have been awaiting formal review since April 05, are we supposed to cease trading until they have decided?

[akpak]

Hi guys

I have just discovered that a large number of our Far East DVRs are not going to be RoHS or WEEE compliant. This basically means that I can get fined for selling them to you and you can get fined for selling them to the End User.

Having researched this for most of the morning I would say that DVRs clearly fall under the banner of 'Control and Monitoring equipment' which provides them with exemption from RoHS. I would also say that a CCTV system is a fixed installation, i.e. it becomes a part of the fabric of a building providing exemption from WEEE.

My questions are the following

Any other manufacturers / importers on here going through the same thing, what conclusions have you drawn?

Any installers here asked to uninstall move and reinstall CCTV systems when a company moves? I think this is rare but I may be wrong. This would form the strong basis of a legal argument regarding the WEEE exemption.

Any help would be much appreciated

Robin

Hello Robin

We are in exactly the same boat, all of our suppliers are now either Rohs compliant (have gone through all necessary testing procedures and have certification) or are currently in the process of gaining certification.

Within a few months I would imagine the vast majority of kit coming out of the far east will be compliant.

AK

http://www.pakatak.co.uk