The Association of Manufacturers and suppliers of Power Systems and ancillary equipment

Workgroup 1 Updates

Workgroup 1 – Materials Compliance Leader: Stuart Hawkins

At the Technical Committee meeting in January, the name of this workgroup was changed from ‘RoHS’ to ‘Materials Compliance’ to reflect its work on WEEE and Battery Directives as well as RoHS.

Proposed revision to the wording of the RoHS Directive:

Application for exemption for lead in bearings (e.g. engine main and big end bearings).

Still no news, we are working with EUROMOT to pursue this. It is now unlikely that the exemption could be issued before the RoHS 2 Directive is effective.

Two further derogation applications to be aware of:

Phthalates in fuel pipework and components. One use of Phthalates is as plasticisers, and they are falling out of favour because of environmental and other problems. There are alternatives, but currently these alternatives are not suitable for certain applications.

Lead in solder – NRMM components with high heat/vibration requirements. Category 11 exemption application for lead in solders used for sensors, actuators, and engine control units (ECUs) in NRMM engines. Some types of professional use equipment contain engines, such as mobile generators, that may have to comply with both the NRMM Emissions Regulation (Stage V) as well as RoHS. As such, this will require replacing sensors, actuators and engine control units (ECU) with alternative designs that use lead-free solders – even though lead-free solders have different performance characteristics than traditional leaded solders and can be unreliable under severe conditions such as those experienced in NRMM engines (e.g. high temperature and vibration) …

Procedure 2017/0013/COD

This is to amend the RoHS Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment. The reason for the change is to prevent the unnecessary production of waste and promote a circular economy, thus Article 4, paragraphs 3 and 4 are revised to add – “and to all other EEE that was outside the scope of Directive 2002/95/EC which is ‘placed on the market’ from 22 July 2019.” Previously this was ‘making available’. *

* The original cast of the RoHS directive would have prohibited any secondary market operations which includes reselling or the second hand market of non-RoHS compliant product after July 22nd 2019, potentially resulting in a large volume of waste. In simple terms, the difference between ‘placing on the market’ and making available on the market’ is as follows:

‘Placing on the market’ is the initial action of making a product available for the first time on the Community market, with a view to distribution or use in the Community.

“Make available on the market” means to supply in the course of a commercial activity for distribution, consumption or use on the EU market.

Products excluded from the RoHS Directive, relevant to AMPS Members, include:

Large-scale fixed installations being a large-scale combination of several types of apparatus and, where applicable, other devices, which are—
(a) assembled and installed by professionals;
(b) intended to be used permanently in a pre-defined and dedicated location; and
(c) de-installed by professionals.

But what does ‘large’ mean? One possible way of introducing a direct size criterion relates to transportation. If the installation exceeds the minimum requirements for one of the following criteria, it could be considered large-scale:

  • If, when installing or de-installing the installation, it is too large to be moved in an ISO 20 foot container because the total sum of its parts as transported is larger than 5,71m x 2,35m x 2,39m, it can be considered large-scale.
  • The maximum weight of many road trucks is 44 tonnes. Thus if, when installing or de-installing the installation, it is too heavy to be moved by a 44 tonne road truck, because the total sum of its parts as transported weighs more than the truck's load capacity, it can be considered large-scale.
  • If heavy-duty cranes are needed for installation or de-installation, the installation can be considered large-scale. Again, there is no definition of what a ‘heavy duty crane’ is.
  • An installation that does not fit within a normal industrial environment, without the environment needing structural modification, can be considered large-scale. Examples for modifications are modified access areas, strengthened foundations etc.
  • If an installation has a rated power greater than 375 kW, it can be considered large-scale. The above is only guidance, there is deliberately no specific definition in the regulations, as each case must be considered on its merits. It is suggested that the generating set etc. documentation justifies and records the decision. It is the obligation of the ‘economic operator’ to comply.

There are other items on the list of excluded items, this is only an indicative list.

Also excluded from RoHS is ‘Non-road mobile machinery made available exclusively for professional use, being machinery, with an on-board power source, the operation of which requires either mobility or continuous or semi-continuous movement between a succession of fixed working locations while working, and which is made available exclusively for professional use.’  This now also includes NRMM with an external power source, but this is not likely to affect AMPS members, we feel.

RoHS 3 is coming!

WEEE Directive – Reminder

See Current Thinking 22/11/17 here [Current thinking WEEE Directive and UK regulations 2WEEE Regulations Amendments 3, WEEE Regulations Amendments Open Scope consultation 4SI Waste Electrical and Electronic Equipment Regulation 5]
Don’t say we didn’t warn you!

The register is public, and thus non-registration can be reported by anyone for investigation…

Declarations of Conformity (DoC)

Some examples were attached to the presentation. The workgroup is considering producing examples of DoC in order to assist members.  Again, any thoughts and suggestions from members would be appreciated.