New regulations and their relevance to the distribution sector

Mercury Regulation … End-of-Life Vehicles Ordinance … RoHS Exemptions

The start of the new year will see the introduction of several new regulations and ordinances, which according to the FBDi, are also relevant to the distribution of electronic components:

The EU 2017/852 ‘Mercury Regulation’ defines measures and conditions for the use and storage of and the trade in mercury, mercury compounds and mixtures a well as the production, use of and trade in mercury-added products. It also contains provisions regarding the safe storage thereof in accordance with waste disposal legislation. The FBDi considers Annex 2 in particular as being relevant to the distribution sector since it governs the import/export and production of mercury-added products and defines a date for the various product categories after which the export, import and production of mercury-added products are prohibited. According to the announcement of November 15, 2017 for various mercury-added cold-cathode fluorescent lamps and fluorescent lamps with external electrodes (CCFL and EEFL) for electronic displays, December 31, 2018 already applies as an expiry date. For batteries/accumulators and switches/relays as well as for electronic measurement devices (e.g. thermometers, axis/inclinometers), the specified expiry date is December 31, 2020.

Directive 2000/53/EC of the European Parliament and the Council regarding ELV (or End-of-Life) vehicles, according to which cars must be almost fully recyclable, defines areas that are of interest to distributors of electronic components that serve the automotive industry. On November 15, 2017, the exemptions in Annex 2 were amended – specifically the exemptions for lead and lead compounds (e.g. lead in dielectric ceramic materials, lead in solders) where the impact is deemed to be significant; these can be found in the exemptions 8 and 10 listed therein.

In Directive 2017/2102 of November 15, 2017, the EU addresses a range of issues that includes amendments to Directive 2011/65/EU (RoHS) on the restricted use of specific hazardous substances in electrical and electronic devices. A new addition that the FBDi sees as particularly relevant to the distribution sector is an exemption list in Annex 3 for electronics. Here, the expiry dates for categories 8 (medicine), 9 (control and measurement equipment) and 11 (new as of July 22, 2019) are defined:

Category 8 and Category 9 for private consumers: max. 7 years validity from the date of inclusion in RoHS (July 22, 2014)
=> Expiry date July 22, 2021
InVitro diagnostic equipment from Category 8 => Expiry date July 22, 2023
Category 9 => Expiry date July 22, 2014
Category 11 – max. 5 years from the date of inclusion in RoHS => Expiry date July 22, 2024

Therefore, in the absence of new exemptions, all exemptions will expire in 2024. However, due to ongoing discussions about the extension of exemptions, these expiry dates are currently merely theoretical and are not valid.

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