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Interpreting the RoHS and WEEE Directives The RoHS and WEEE Directives are not long to read, but comprehension is another issue. The company relies upon experts in the field and guidance documents from government agencies. Much of what the company has learned came from two documents. The Department of Trade and Industry (DTI) in the United Kingdom authored RoHS Regulations—Government Guidance Notes in November of 2005. In May 2006, the RoHS Enforcement Guidance Document was produced. The first step is to learn the equipment categories covered in the Directives. The WEEE Directive lists the equipment, but there is no mention of them in the RoHS Directive. However, the guidance documents suggest that the WEEE list can be used with the RoHS Directive. Categories of Electrical and Electronic Equipment In Annex IA of the WEEE Directive, ten categories of electrical and electronic equipment are listed. They are shown in Table 1 (EEE Categories).
*Not covered by the RoHS Directive. In Annex IB, specific types of products are listed under the major categories. By examining the two lists, the company has identified several potential areas under which Contemporary Controls' products may apply. Although no hub, switch, media converter, router, gateway, or network adapter products are listed under category 3 (IT equipment), it is possible to say that the company's products could be classified under "other products and equipment for the collection, storage, processing, presentation or communication of information by electronic means." Certainly, these products provide "communication of information by electronic means." The hub, switch, media converter, router and gateway products are stand-alone products that receive external power and begin functioning when connections are made. The network adapters are different in that they must be inserted into another piece of equipment in order to function. The ten category listing of products identify end-user products. They do not specifically address devices used to support these end-user products. For example, the company's products are used in applications found under category 8 (Medical) and category 9 (Monitoring and control instruments). It is also possible to find the company's products in large stationary tools which are exempt from category 6 (Electrical and electronic tools). All of these application areas are exempt from the RoHS Directive. Therefore, we need to study the exemptions closer.
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