At Newey & Eyre we want to reassure our customers about the steps we have taken to prepare for the RoHS Regulations. Essentially, we have done the hard work so you don’t have to.

Overview

There has been much confusion about the scope of the Restriction of the use of certain Hazardous Substances (RoHS) Regulations which come into effect on 1st July 2006. As a result, many customers working with electrical products are confused about what they specifically need to do to comply. In many cases, customers are requesting material declaration certificates, product labelling, testing conformity certificates and in some cases recycling in order to comply. Requests received are very inconsistent, in terms of the level of information required and in some cases because of the way they are presented. This makes it difficult to respond clearly and concisely from the perspective of a business such as ourselves.

This explanatory note has therefore been compiled to explain how we have addressed the requirements of the Regulations and to reassure customers about the practical aspects of RoHS in relation to an electrical distribution business such as Newey & Eyre. Our intention is to be transparent and clear about the practical implications of the Regulations and by doing so, reassure our customers about the quality service they can expect from our business at all times.

Notes about the Regulations

The RoHS Regulations require producers (a manufacturer, an importer or someone selling an own brand) to ensure that any product that falls within scope is manufactured without using certain hazardous materials above specified concentration levels - unless there is a specific exemption. This creates two key factors to consider, firstly who is the producer and secondly what products do the Regulations cover (scope).

Who is the Producer?

A producer is the business who either

A) Manufactures the product
B) Resells under their own brand, or
C) Imports the product.

We are classed as a producer for our own brand products, i.e. Newlec, Eski & Defiance, which are unique to our business. However we do not manufacture products, we only distribute. For this reason, for any item that is not one of our own brands, it is the brand supplier, (Thorn, MK, etc) who is responsible for the products that they sell through our business. Our primary focus is therefore on our own brands where we have direct responsibility.

We do however recognise our duty of care to provide information on behalf of our other suppliers, even though we do not have legal responsibility to make declarations on behalf of these suppliers nor do we have any manufacturing liability for them.

What products do the Regulations cover?

In general terms, the Regulations cover any of the following indicative products:

CATEGORY 1: Large Household Appliances

CATEGORY 2: Small Household Appliances

CATEGORY 3: IT And Telecommunications Equipment

CATEGORY 4: Consumer Equipment

CATEGORY 5: Lighting Equipment

CATEGORY 6: Electrical And Electronic Tools

CATEGORY 7: Toys, Leisure And Sports Equipment

CATEGORY 10: Automatic Dispensers

What is not covered by the Regulations?
It is important to understand that RoHS does not cover all electrical products. There are also some clear exclusions. Whilst it is not appropriate to provide technical detail in this format, we would like to highlight what we feel are the most common exclusions and misunderstandings.

A) Fixed installations or components, parts or materials that form part of a fixed installation are excluded from the requirements of RoHS. A fixed installation is something that needs to be professionally installed and cannot operate independently from the installation. If the unit is not intended for supply onto the market as a separate functioning unit and can only operate as part of fixed installation, it is not covered.

Example: an alarm panel within a security system or an air conditioning unit that forms part of an overall system.

B) Monitoring and measuring devices are excluded from RoHS. There has been significant confusion about this subject because the RoHS Regulations draws its scope from another set of Regulations that has yet to be introduced. Whilst the WEEE Directive will include Monitoring and Measuring Devices, the RoHS Regulations do not, so anything falling into this category does not need to comply with RoHS. There are a large number of products that we supply which fall into this category.

Example: test instruments, heat detectors, control and automation switchgear etc. are all monitoring devices.

C) Non-electrical products are not part of the RoHS Regulations. This might sound fairly obvious, but the Regulations are very specific about what constitutes an electrical product. If electricity only provides a support function and is not the primary function, it is not electrical (e.g. a light up pair of trainers). Likewise, if the item does not use electricity to function it is not part of the Regulations.

Example: cable conduit, or surface mounting boxes that might be associated with electrical products but themselves are not electrically operated.

D) Components are not part of the RoHS Regulations, only products are. This is a common misunderstanding. There is no legal requirement to make sure that components comply. However, if the component is likely to be used to make a product that is within the scope of the Regulations, by default it will need to comply for commercial reasons. So whilst manufacturers of components might not have legal accountability, commercially they will need to respond if the component can be used to manufacturer a product that is covered in one of the categories.

E) Anything that does not fall under one of the category headings of the Regulations, even if it is electrically operated, does not need to comply with the Regulations. This is another common area of misunderstanding. An enormous number of the products we supply do not fall into any category even where they are electrically operated.

Example: an electrical extension lead.

There are other products which require a bit more thought, for example an industrial water boiler which on fi rst glance might be considered to fall under the household appliance section with kettles etc, but on closer examination is not a household product and is therefore not covered. There are many other products typically associated with electrical distribution that do not fall within the scope of the indicative category listings.

Our Own Brands

At Newey & Eyre we have a number of Own Brand product ranges - Newlec, Eski & Defiance. We have a responsibility to ensure that our own brand products comply with the requirements of the RoHS Regulations where they fall within the scope of these Regulations. We have therefore carried out an extensive exercise to assess our products against the necessary requirements in conjunction with our supply partners.

From July 1st 2006, for those of our products that do fall within the scope of the Regulations, we can confirm that they will be compliant.

Other Manufacturer Brands

As an electrical distribution business we do not manufacturer products ourselves. The RoHS Regulations require our manufacturers to ensure that products that fall within the scope of the Regulations, comply by 1st July 2006. We have spent considerable time and effort working with our suppliers to address these issues over the last 2 years.

We offer in excess of 200,000 product lines that are sourced from literally hundreds of suppliers. Whilst we have a duty of care to our customers for passing on supplier information, we are very much reliant on our suppliers to adopt legal requirements in relation to their own products as they are the technical experts in their own fields. We have taken all necessary steps to address this issue and now have complete confidence in our supply partners.

Over the last 2 years we have systematically communicated with all of our suppliers and raised awareness of the RoHS Regulations. To date we have not received a single response from any of our suppliers that suggests anything other than a full and complete commitment to meeting the requirements of the RoHS Regulations by 1st July 2006 - where their products fall within the scope of the Regulations. We are therefore confident in passing on our suppliers’ commitment to all of our customers.

To find out more download Newey & Eyre's - A Guide to RoHS Regulations

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