ARC Control, Frequenty Asked Questions

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Exemptions to the RoHS Directive

The DTI documents provide good guidance on the exemptions. Some exemptions only provide short-term relief, but they can be helpful as the industry struggles to achieve RoHS compliance. For most products, it is quite clear whether or not the product falls under the scope of the directive. However, for specialty industrial products it remains unclear. Contemporary Controls' products are a good example.

Of the ten categories of products listed under the WEEE Directive, only eight fall under the scope of the RoHS Directive. The Medical and the Monitoring and Control categories are exempt. These are two areas where Contemporary Controls' products are used. In fact, under Annex IB in the WEEE Directive, examples of monitoring and control equipment includes "other monitoring and control instruments used in industrial installations (e.g. in control panels)." All of Contemporary Controls' products, except for network adapters which mount into other equipment, are intended to be mounted in control panels. Network adapters installed in industrial controllers could then be mounted in control panels. Other guidance has been provided on the subject.

If the equipment in question is part of another type of equipment which is exempt, then the parts that make up the exempt equipment is also exempt. For example, if a Contemporary Controls' product is used in a monitoring or control application, the product would be exempt from both the RoHS and WEEE Directives.

The concept of the "fixed installation" was addressed. A fixed installation may be a combination of several pieces of equipment assembled together by a professional assembler at a particular location to perform a specific task. Since this installation is not being put on the market as a single commercial unit, it is exempt from the RoHS and WEEE Directives. In most automation projects, the intent is to improve a system's productivity within a customer's plant, factory or process line. There is no intent to market the automation system as a single commercial unit. Therefore, a Contemporary Controls' product used in an automation application is exempt from the Directives. The same can be said of "large stationary tools" which are exempt from category 6. Because they represent a fixed installation, they and their component parts are exempt from the RoHS and WEEE Directives. The guidance document expands the fixed installation definition to include "a machine or system, consisting of a combination of equipment, systems, products and/or components, each of which is designed, manufactured and intended to be used only in fixed industrial applications." These types of systems are exempt and therefore the components in them are exempt.

Another key exemption relates to spare parts and the expansion of an existing system. This typically occurs when industrial networks are expanded in the field. This situation has applicability especially with the company's mature ARC Control product line with its numerous customer installations. Expansion boards for the company's chassis hubs are still available for enlarging an existing installation. Spare parts, replacement parts, and parts to expand existing installations are also exempt from the RoHS Directive. This is important since some of the ARCNET components are not available lead-free and yet customers intend to enlarge their systems.

Finally, there is the issue of category 3 (IT and telecommunications equipment). End items (the company calls them end stations) such as personal computers, printers, fax machines, telephones, and other such devices are included in the scope of the RoHS Directive. Those items that support network infrastructure are not included in the RoHS Directive. This is interpreted to mean hubs, switches, media converters, routers, and gateways.

From the above decision, it would appear that Contemporary Controls' products are exempt from the RoHS Directive. However, the company's position is that the customer must decide if RoHS compliance is required. The company's products can be applied in numerous ways, and how it is applied determines if RoHS compliance is a requirement. A customer may insist upon a lead-free product in order to meet the needs of his own "green" initiative and Contemporary Controls hopes to comply with the request. Other customers may accept either a leaded or lead-free product or insist upon leaded products. They are the responsibility of the customer to make the best informed decision as to compliance requirements. It is Contemporary Controls' responsibility to ensure that a product marked as "RoHS Compliant" is indeed RoHS compliant. This is where due diligence comes in.