Conformity Magazine - March 2008 - (Page 29)

• Polybrominated biphenyls (1000 PPM) • Polybrominated diphenyl ethers (1000 PPM) These, of course, are the familiar six substances restricted by the EU in directive 2002/95/EC, the RoHS Directive. In fact, they were deliberately chosen to conform to EU RoHS, and the Korean legislation’s exemptions correspond roughly to the European equivalents as well. Examples of the exemptions include lead in ceramics and glass of electronic components, lead in solders of servers and telecom infrastructure, and mercury in compact fluorescent lamps. However, it is suggested that manufacturers or importers of products using RoHS exemptions should review all exemptions against the Korean list to be sure they are still applicable. It is also worthwhile to note that, similar to the EU Directive, Korea RoHS measures the concentration at a homogeneous level, meaning that crush tests are not useful to determine compliance of a product or component. “Environmentally Conscious” Design Requirements Perhaps the one aspect of the Korean legislation whose impact is most unclear at this time is its Energy-Using Products (EuP) -like “environmentally conscious design” provisions. The requirements will be provided in the as-yet unpublished Technical Guidance on the Improvement of Materials and Structure. Although the document itself is not available at the time of this writing, its scope can be inferred directly from the legislation. Technical Guidance will require the selection of materials that are readily recyclable, in a design that is easy to disassemble. Materials will need to be marked, and should be chosen to minimize the overall number of materials. Notably, the emphasis in the Korean Act appears at this time to be on choice of materials to maximize recyclability. This is in contrast to the European equivalent, the EuP Directive, where the emphasis is on energy efficiency. The Korean Ministry of Environment is authorized to require reports on implementation of the Technical Guidance’s requirements when it deems it necessary, and is also authorized to require conformity when it determines that not enough effort was made. This could theoretically remove products from the Korean market until redesigned! Recycling Obligations The enforcement ordinance requires far greater detail in treatment instructions for recyclers than the EU’s Waste from Electrical and Electronic Equipment (WEEE) Directive. The Korean legislation requires, among other things, complete disassembly instructions. This is a significant step beyond the requirements of WEEE treatment instructions, and it is therefore inappropriate to assume that the Korean legislation can be covered by existing WEEE treatment documents. Furthermore, there is a maximum allowance of one month to register the treatment instructions in Korea after a request has been made by a recycling group. This has the effect of requiring treatment instructions to be written as new products are introduced, as for many products, one month is a short period of time to produce complete and accurate dismantling and treatment instructions. The registration must be made with the Korean OMIS, or treatment instructions made available on the producer’s website or shipped with the product in electronic or printed copy. Other requirements of the treatment instructions include a listing of all hazardous substances, their location and removal methods; a listing of all structural plastic parts, their type and removal methods; and efficient processing and recycling methods for recyclable materials. The Enforcement Ordinance sets mandatory recycling recovery rates. Manufacturers and importers are required to meet – and document – quotas for the amount of e-waste reclaimed vs. produced. The “Recycling Obligation Volume” is set by the Korean government and varies by product type. A fee-based tax structure is described, in which the costs of recycling are moved onto the producer or exporter, according to the category of product. marCh 2008 Conformity 29 http://www.pseinc.com http://www.pseinc.com

Table of Contents Feed for the Digital Edition of Conformity Magazine - March 2008

Conformity Magazine - March 2008 NewsBreaks Editor's Note Adelstein Renominated to the FCC Industry Canada Publishes FAQs On RF Fields FDA Gives Its Scientific Capabilities Poor Marks FDA Offers Guidance On its Product Review Process FDA Publishes Updates to List of Recognized Standards FDA Warns of Patient Risk From Electric Dental Handpieces Complying with the EMC Directive, Second Edition ESD Open Forum Emerging Issues in Standards - Korean "RoHS": Not Like RoHS at All The iNARTE Informer Challenges in Testing - Field-Induced Charged Device Model: What Really Happens Design Fundamentals - EMI Shielding Technologies for Consumer Electronics Equipment Focus On...Compliance Software Buyer's Guide Additional Standards Published for the EU's ATEX Directive Additional Standards for the EU's Medical Devices Directive Also Published China to Require Bar Codes to Enhance Product Safety CPSC Releases 2007 Self-Assessment CPSC Actions in News IEC Standards Update UL Standards Update Product Reviews Telcordia Standards Update From Our "You Can't Make This Stuff Up" Department Looking Back: Items from Past Issues of Conformity Advertisers

Conformity Magazine - March 2008

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