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WEEE & ROHS Compliant or not ? (manipulating tool)

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WEEE & ROHS Compliant or not ? (manipulating tool) | 11 October, 2005

I know this could not be an SMT thread, but in certain way it impacts the PCB/PCBAs Assemblers.

Hello everybody,

who could help me please to identify if this tool Mmust be or Not compliant with the WEEE and ROHS Eu Directives ?

I can define this a: Manually controlled load manipulating Tool. (4 plus 2 or 4 Axis). Like a manipulator robot handily driven by operator. Used for instance to assist operator lifting weights (boxes, tools) to assist carton box rigging, to assist operator during mechanical parts assembly, etc) . Some time they are fixed on the floor, integrated on moving cranes, or fixed on walls or column.

There are a totally Pneumatic powered models and Electrical (plus servos) powered models. I found basic description in the CEN European Standards EN 14238 : 2004 (E) (prepared by CEN/TC-147 held by BSI)

By referring to WEEE 2002/96/EC Annex IA and Annx IB, Category 6. Electrical and Electronic tools (with the exception of large-scale stationary industrial tools ) it is not so clear how to identify which category belong such tool/equipment .

Category 6 description:

- Drills, Saws, Equipment for turning ,milling, sanding, grinding, sawing, cutting, shearing, drilling, making holes, punching, folding, bending or similar processing of wood, metal and other materials.

-Tools for riveting, nailing or screwing or removing rivets, nails, screw or similar uses

-Tools for welding, soldering or similar use

- Equipment for spraying, spreading, dispersing or other treatment of liquid or gaseous substances by other means

- Tool for mowing or other gardening activities.

As you can see they do not talk about : robots, manipulating system, lifters, crane, elevators, etc. (Very clear example of an easy Directives' interpretation !!!).

I'll appreciate any help and advice. Many Tnks in advance.


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WEEE & ROHS Compliant or not ? (manipulating tool) | 11 October, 2005

I would interpret the directive such these manipulating arms are "tools" as described in cat 6. The next step would be to investigate whether or not your competitors (or other suppliers) are claiming to be WEEE and RoHS compliant. If they are and your not then the whistle will blow!

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WEEE & ROHS Compliant or not ? (manipulating tool) | 14 October, 2005

This is interesting. First - you should not mix RoHS with WEEE directives. One have no relationship to the other. But in contradiction it have. I must study this matter more closely before I can present an answer and this may take some time, let say WEEEks.

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WEEE & ROHS Compliant or not ? (manipulating tool) | 24 October, 2005

Thanks Gents for your replies,

first of all I am not involved in production or sale of those tools. It was just a discussion during one of those so many "panic full" work shops / symposiums on WEEE and ROHS matter organized by material or SMT equipment Vendors. You can imagine all the arguments are mainly driven by lead-free alternative materials, wave solders, reflow ovens, but not so much in order to help understanding if OEM/EMs (mainly the smaller) SHOULD or HAVE or MUST produce their Tools in compliance with WEEE & ROHS Directives, often at the end of the day you can see EMs scared more then supported by those fellow's news. The manipulator was just an example. Automatic driven gate could be another, etc In my opinion to produce a Manipulator (Electronic Type) see an example in the link

in accordance with Directives it could be done but because it has to manipulate weights (lifting) I suppose it has to be compliant with his Category of tuff Safety regulations. So in my opinion who solders electronic stuffs by removing Lead, he has to submit product to severe Reliability tests, this means plenty of additional costs. So the question can be, why to spend money to get a W&R compliance Tool when it may be it is not required ? Yes, true, it could be strategic to have a green product available to market but who ( in this not so happy economic season ) has money to invest?). EEE Categories descriptions in WEEE annex IA, IB, allows for many interpretations. For example Easy to decide if we are talking about a domestic Coffee machine and Bar Coffee machine, but when lifting weights assisted by operator it involves more severe safety normative.

Ola: About mixing WEEE and ROHS directives, your comment is correct, yes one takes care about wasting regulations of EEE the other takes care how to prevent/reduce hazardous subsatnces in the EEE. But also you know very well that ROHS refers to WEEE Annex I-A and I-B as a descriptions of those Categories of EEE who have to be compliant with ROHS. Believe me, the Confusion is very diffused among all and many of the EEE Producers are not yet aware that their Products fall into this painful EU Directives.

Plenty of local or international private agencies or consultants are growing like mushrooms, but with the target to make own businnes (correct, it is a good opportunity) more then help small EMs or Producers . And were are the EU Organizations, Governmental National Organizations, etc. ? Who is able to contact Brussels (TAC experts) in order to get support, for instance, in situation like this ? It may be only the Large OEM and EMS are able to do it but not those small Companies that probably or for sure will have to close up the shops/companies before 1 July 2006 because not more profitable to produce in Compliance with those Directives or probably they will decide to import products from low cost geographic area.

Sorry for my poor English but my mother tongue in one of those 25 different languages spoken in EU other then English. Hope you understand what is the meaning and the spirit of my this " boring " story about WEEE & ROHS. Any way if you have some advice, news on this matter (electrical manipulator) I will appreciate it.

Thank you

Best Regards.......GS

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WEEE & ROHS Compliant or not ? (manipulating tool) | 25 October, 2005


Let me tell you first and for all your English is perfectly ok (better then mine). Europe might be unified (on paper as a nation) but I bet it must be difficult to communicate when you have 25 different languages. Maybe this explains why the RoHS/WEEE directive is so unclear.

I believe the equipment you mentioned falls under the "Fixed Installation exemption" as where large scale industrial tools becomes part of an other item outside the scope of the directive (in this case the building where it is attached to). The biggest problem you will face is that there is no unity among the EU member states in adopting exemptions. If they decide to adopt the criteria to say that their products are outside the scope of the directive they will have to document the decision-making process, allowing them to present clear evidence should they be challenged.

Good luck and encourage those people to keep on building reliable equipment. Patrick.

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