Regulation again

John Page · 22-06-2006, 04:17 PM

No apologies for returning to regulation again. It's important to the UK and EU economies, and will be a main concern of UKIP's Business Forum, announced in the latest Independence News.

The EU's regulation régime may just have received a couple of jolts. I've written about them in my blog today.

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http://thepurplescorpion.blogspot.com/

John Page · 23-06-2006, 12:10 PM

All this regulatory complication costs us money. Here's a snapshot of how ridiculous it is.

Quote:

RoHS exempt or not, that is the question?
by Gary Nevison, Farnell InOne
Friday 23 June 2006
One of the most hotly debated RoHS topics of the moment, and arguably one of the most confusing, has to be the issue of exemptions and what is in or out of scope. Being exempt from the challenging environmental legislation may seem like a dream come true but get it wrong and you could be in trouble.

Currently categories 8 and 9 are not within the scope of the RoHS legislation – but do fall within the WEEE Directive. However, a review is currently taking place for the European Commission by ERA Technology and it could well be that these are included, around 2010.
What are the challenges involved in assessing what is exempt or not in scope and how can people keep track of the changing status of products?

Where there is no technical alternative for specific materials used in products, the RoHS legislation permits exemptions. This means that if there is genuinely no viable alternative for a material required for a particular application, manufacturers can request an exemption for this specific application (the product itself will not be exempt). Of course, this provides manufacturers with some longed-for extra time to solve technical problems and find substitute materials or designs, but it must be remembered that exemptions are not your ‘get out of jail free’ card. All exemptions are temporary and are reviewed by the European Commission every four years. If a substitute then exists, the exemption will be terminated.

If you think a part or material used in a product that you manufacture could be exempt from the legislation there are a number of steps you need to take. Initially you need to check whether the product in question even lies within the scope of RoHS. Categories 8 and 9 covering medical devices (with the exception of all implanted and infected products) and monitoring and control instruments are excluded from RoHS, therefore if your product falls within either of these categories you need not worry (for now). But how do you decide if what you produce is included in these categories?

Examples given of medical devices are as wide and varied as to include radiotherapy equipment, dialysis, fertilization tests and nuclear medicine. However, this list is by no means exhaustive and it must not be forgotten that the directive applies to the end use of the product, not what it is designed for. For example, there have been occurrences in which equipment designed for medical use, such as a dentist’s drill, has been found to be perfect for other functions, such as cleaning fossils in a museum (therefore as an electronic tool). In this instance the drill would be subject to the RoHS legislation as it is not being used for a medical purpose, although that was the original intention.

If your product does fall within the scope of the Directive but you feel there is no viable technical alternative for specific materials used in it, the next step is to check the list of approved exemptions. The RoHS Annex, a list of applications in which products are considered to be exempt can be found on the European Commission website. This website includes the original directive and subsequent “Commission Decisions” which have published additional exemptions. If you have reviewed this list and your query has not been answered you will also find a list of proposed exemptions on this website. This page has links to the four exemption stakeholder consultations. There are approximately 80 exemption requests on file with more appearing week by week.

If after investigation you find the application is not exempt or a request pending, it is possible to request a new exemption, this will involve submitting written justifications and detailed technical assessments (in particular why apparent substitutes are unsuitable) to the European Commission. If a request that you support is pending, it is a good idea to write to the Commission in support of it. However, please do not forget that until the exemption is granted, producers cannot rely on these. Products that are considered to be within the scope of RoHS should not contain the six restricted substances unless they are used in exempted applications. The National Weights and Measures Laboratory will be the RoHS enforcement body in the UK, and would not permit non-compliant equipment to be put onto the EU market after the 1st July 2006. It is advisable to err on the side of caution and, if you are in any doubt, consulting an expert, such as ERA Technology, or the European Commission itself is a must.

Remember, exemptions are temporary and the inclusion of all products in the RoHS Directive is a case of ‘when’ not ‘if’. Time is running out but it is not too late to become compliant. The deadline to compliance is just around the corner and when dealing with this Directive ignorance is certainly not bliss.
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John Page · 29-06-2006, 10:33 PM

UKIP should be explaining loudly why the RoHS Directive is bad.

Quote:

EU's new electrical rules spark confusion
By Gráinne Gilmore
TRENDY young things may change the selection of music on their MP3 players as often as their socks, but from this Saturday, MP3 players themselves will have to be different.

Though high street shoppers are unlikely to notice much difference — except, perhaps, a change in prices — the tiny electrical components in their new players will have been altered to comply with new European rules.

*
But fears are growing that thousands of small electrical manufacturers and importers could be forced to halt business because of confusion over applying the European Commission directive behind the changes.

The Restriction of Hazardous Substances directive (RoHS) aims to prevent the use of six substances, including lead and cadmium, in the making of electrical equipment. Lead is often used as solder on circuit boards, such as those used in MP3 players, and as a softener in PVC cabling. Cadmium has been used as a colorant for plastic.

Business groups welcome the motive behind the directive — to limit the use of some of the most significant pollutants in electrical goods — but they are dismayed at the confusion surrounding the introduction of the new rules.

Although large firms have the resources to cope with the changes, experts say, small business owners have found it more challenging to comply.

Gary Booton, director of health, safety and environment at EEF, the manufacturers’ organisation, said: “The objectives of the rules are perfectly laudable, but many companies which have made applications for exemptions (to the Commission) in a timely fashion are unlikely to receive a decision before Saturday.”

While there are blanket exemptions from the RoHS rules for monitoring and control equipment, such as burglar alarms, landfill gas analysers and all medical equipment, the Commission’s technical adaptation committee has already granted many further exemptions for some firms to use some of the prohibited substances under certain circumstances.

Yet although the committee is unlikely to consider all applications before Saturday’s deadline, the Department of Trade and Industry has not indicated that companies that have not yet had a response to their application will have any leeway. However, it says it is pressing the Commission to act quickly.

Mr Booton said: “There has to be an acceptance that in some instances these materials are used for purely technical reasons, not because they look nice. All we are asking for is a reasonable approach while companies wait to hear if their application has been successful.”

Mark Shayler, of Eco3, an environmental consultancy, said: “Firms who are waiting to hear about their application cannot just change their working methods overnight. Their business may be forced to halt.”

Businesses that import electrical goods may also be disrupted. Mr Shayler said: “There is a particular threat for importers of electrical equipment where non-compliant products are still being shipped in. Unless they clear customs in the European Economic Area by Saturday, they will not be able to be sold on the market, as it is the date of arrival that is key rather than the date the product was ordered.”

UK electrical manufacturers that fall foul of the new rules will be liable to a fine of £5,000 on a summary conviction, or an unlimited fine if they are found guilty by a jury.

They may well look across the Channel with envy. French firms that do not comply with the RoHS rules will be fined no more than €1,500 (£1,000).

Equally, UK firms will be relieved that they are not in Ireland, where directors of firms that break the rules face up to ten years in prison.

High street prices of electrical goods are likely to rise as manufacturers cover the costs of replacing the banned substances.

Companies will also have to foot the bill for due diligence. Mr Shayler said: “Our research shows that the cost of manufacturing electrical goods is likely to rise by about 5 per cent — but Chinese manufacturers that have changed their working practices to comply with the rules are saying their costs have risen by 30 per cent.”

Watch another disaster unfolding.

John Page · 17-07-2006, 12:19 PM

Booker on asbestos again - can't find it on line yet but I've commented on my blog.

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http://thepurplescorpion.blogspot.com/

John Page · 04-08-2006, 05:36 PM

Even Italy is doing some deregulating.

Quote:

The Economist writes on the successful deregulation of various “vested interests” in Italy through the recently passed “Bersani decree”. This has introduced greater competition amongst taxi-drivers, chemists, lawyers, vets, notaries, banks and bakers. It is estimated the reforms will benefit consumers to the tune of €1000 per family.

I've been arguing UKIP should do some adult campaigning on deregulation.

But if the best we can do is toyshop stuff like today's release on the new postal rates, we may as well give up hope for an adult party.

17-07-2006, 12:19 PM	#14 (permalink)
John Page Senior Member Join Date: Nov 2005 Location: Welwyn Hatfield (Herts.) Posts: 1,878	Booker on asbestos Booker on asbestos again - can't find it on line yet but I've commented on my blog. ---------- http://thepurplescorpion.blogspot.com/

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22-06-2006, 04:17 PM	#11 (permalink)
John Page Senior Member Join Date: Nov 2005 Location: Welwyn Hatfield (Herts.) Posts: 1,878	No apologies for returning to regulation again. It's important to the UK and EU economies, and will be a main concern of UKIP's Business Forum, announced in the latest Independence News. The EU's regulation régime may just have received a couple of jolts. I've written about them in my blog today. ---------- http://thepurplescorpion.blogspot.com/