PCB recycling and WEEE compliance

Fusion Ed · Post by **Fusion Ed** » Wed Jun 04, 2008 5:18 am

Matt,

In the UK (and I believe Europe) anyone who imports/distributes "Electrical and Electronic Equipment" must comply with the WEEE directive.

http://www.weeecare.com/documents/The%2 ... 20WEEE.pdf

[quote]
You must:
â€¢ ensure that EEE you put onto the UK market is marked with a â€œcrossed out
wheeled binâ€

Matt · Post by **Matt** » Wed Jun 04, 2008 12:56 pm

I think that CE compliance may require ROHS compliance (which we are not at the momment)

So does that mean that WEEE is on top of ROHS or we dont need to be ROHS compliant if we are WEEE compliant? Something I'll have to look into

Our components are ROHS compliant but the solder masks on the PCBs and the solder used to load the boards contain lead. It is very difficult to hand solder boards with lead free solder due to the lack of flow

Interesting this is that our boards are soldered into customer ECUs which themselves contain solder anyway (but after reading ROHS documents the daughterboards still need to be compliant since they are a new component)

Fusion Ed · Post by **Fusion Ed** » Wed Jun 04, 2008 8:21 pm

You dont need ROHS compliance for car automotive electronics IIRC. ECU's etc are exempt (for obvious reasons)

I'm 99% sure that's the case.

Matt · Post by **Matt** » Wed Jun 04, 2008 10:04 pm

That is good if that is the case. I've been looking it up and would be considered control electronics which is ROHS exempt. Here are the extracts appliable to the boards from http://www.rohs.gov.uk

There is a flow chart with 10 categories under low powered applications, which are required to be ROHS compliant. Fortunately ECUs or daughterboards do not fall under any as you mention and also in regards to WEEE

Also I looked through the rest of the documentation for other exclusions:

Equipment specifically designed to be exclusively installed on airplanes, boats, cars and other forms of transport (ie not falling within one of the Categories of EEE) is not considered to be within the scope of the RoHS Regulations.

WEEE FAQ

1.2. What are the criteria for determining whether a product falls under the
RoHS Directive?
Spare parts for the repair, or the reuse, of electrical and electronic equipment put on the market from 1 July 2006.
[RoHS Art. 2.3]
The Directive does not apply to parts for use in equipment put on
the market before 1/07/2006 with the purpose of extending its life by
updating its functionalities or upgrading its capacity.

The daughterboards allow the reuse of existing equipment for ROHS

In regards to WEEE

If the â€œother type of equipmentâ€

Fusion Ed · Post by **Fusion Ed** » Thu Jun 05, 2008 10:10 am

This is good news. So it appears as if WEEE compliance is not necessary. RoHS I was not worried about as I had looked into this before the regs came in.

When I get a chance I shall make some enquiries as to the specifics on the WEEE directive just to have it as documented proof, but it seems at least at this stage that there is no need for concern.

Ed

Matt · Post by **Matt** » Thu Jun 05, 2008 4:18 pm

Yeah ROHS and WEEE have similar rules in regards to whether they apply or not. I havent looked into CE yet (this has to do with EMI?)

Fusion Ed · Post by **Fusion Ed** » Fri Jun 06, 2008 2:26 am

Here is a good start:

http://en.wikipedia.org/wiki/CE_mark

Fusion Ed · Post by **Fusion Ed** » Fri Jun 06, 2008 2:37 am

It seems that the "e" mark would apply to NIStune rather than the CE mark.

The Automotive EMC directive

Summary

The Automotive EMC Directive is a CE marking Directive that requires manufacturers to gain type approval for all vehicles and electronic sub assemblies, components and separate technical units to be used in vehicles.

So with that:

Products that have direct control of the vehicles must not emit EMC emissions above the specified limits and must be immune to the interference levels stated in the Directive. However, products without direct control only have to meet the emission requirements. The Directive contains 3 groups of tests and states their acceptance levels. They are; narrow band emissions, broad band emissions and immunity tests.

Know any friends that work in EMC testing

anyway I have a feeling that it would be the responsibility of me, I.e. an importer/distributor rather than you (since your outside the EU) to ensure compliance. In any case there is lots of information here:

http://www.conformance.co.uk/directives/ce_autoemc.php

Fusion Ed · Post by **Fusion Ed** » Fri Jun 06, 2008 3:01 am

To add even more to this, its opens up a gaping hole really in the importation of any in car electronics (since the responsibility once within the EU will lie with the person/company importing the goods.) It appears that no one is aware of bothers to comply with this, for even items such as Apexi ecus boost controllers or any Greddy kit. I have never seen anything of that e-marked at all.

Ed

Matt · Post by **Matt** » Fri Jun 06, 2008 2:12 pm

It appears to me out of the EU the UK has been the only one really pushing for enforcement of ROHS/WEEE. All other EU countries do not have ROHS import restrictions specifically stated on postal items.

I'll have a look at the CE stuff and see if there is anything we can do. We have had EMC issues with previous Type 4 boards which is why we had to introduce ground planes and adaptor boards to get around this. The emissions should not affect the ECU nor should they leave the casing of the ECU. But that would require proper certification for each Type board

As you mention, I do not see this with any other automotive products (specifically made in USA or Japan) which are sold worldwide

Fusion Ed · Post by **Fusion Ed** » Sat Jun 07, 2008 5:20 am

Quite, it seems that people are leaving themselves open to trouble by ignoring these rules. I however brought this up in the first place due to a UK company supplying components for FM broadcast who were just taken to court and fined Â£10,000 for lack of RTTE/CE compliance, with Â£90,000 costs (thats a cool AUS 239,000$), even though it was a module sold as intended to be installed into other equipment, obviously its caused quite a stir.

Matt · Post by **Matt** » Fri Jun 13, 2008 3:49 pm

On paper it looks like that we would need to get AEMCD approval as you mention

The only exception is

If the equipment does not have a electronic oscillator with an operating frequency greater than 9 kHz, it is considered to comply with the narrow band emission requirements without further testing.

Type 2-4 daughterboards do not have an electronics oscillator. Type 1 does for the FTDI USB chip

Regardless they are being fitted to an engine control unit with an oscillator accessing the memory on the boards at those frequencies

This looks to require a test shop. But how would they measure EMC? You would be measuring the ECU itself right? Because the ECU is the one which runs the frequencies which the board is dependent on. But that would mean testing the whole ECU, which itself is not AEMCD approved...

So I guess the question is, is it a requirement to be have AEMCD compliant subcomponents to a non-AEMCD compliant piece of equipment. If so, how if that tested for EMC when the subcomponent cannot be run without the equipment?

Fusion Ed · Post by **Fusion Ed** » Mon Jun 16, 2008 6:37 am

Good point, I think contact with a test house may be needed for some advice.