As another year draws to a close we have the chance to look back at 2014 and the legislative measures that had an impact on our industry.
RoHS2 (Recast) and Conflict Minerals were probably the main areas of activity but there were others, such as WEEE and Batteries, and several other directives were the subject of recasts.
RoHS2 saw the introduction, for the first time of categories eight (medical devices) and nine (monitoring and control instruments) the latter with a focus on consumer products. Products that were already “in stock” did not have to meet the obligations of RoHS2 which was implemented on 2 January 2013. Only those put on the market after 22 July 2014 were captured within scope.
Industrial or monitoring and control instruments for professional use will fall in scope three years later on 22 July 2017.
Those placed on the market will need a declaration of conformity and include all the information required in the technical file, as part of the CE requirements.
The Conflict Minerals or ethical sourcing rule in Europe is running a little late although the implementation of legislation is still expected next year. Much of the debate has been around whether there should be a voluntary or mandatory approach. At present the CMRT (Conflict Mineral Reporting Template) is still the most frequently requested document.
WEEE2 (Recast) has an updated list of Frequently Asked Questions covering scope, definitions, collection, treatment facilities and monitoring and inspection requirements. The hot topic is the definition of dual use and the Department of Business Innovation and Skills in the UK are hoping to publish guidance early in the New Year.
Moving on to REACH the latest forecast is that there could well be 440 SVHCs (Substances of Very High Concern) by 2020. This will show significant progress compared to the 155 today.
The amended Battery Directive will remove the exemption for cadmium in cordless power tools in 2017 while the mercury in button cells exemption will end in 2015.
With Recasts on the horizon for EMC, LVD and other NLF (New Legislation Framework) Directives both 2015 and 2016 look as though they will be hectic for Legislation Officers and their colleagues.