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RoHS 2015 Implementation at Schneider Electric

Published date: 23 May 2019

What is RoHS 2015 amendment?
RoHS 2011/65/EU is a European Directive which restricts the use of chemicals in electric and electronic equipment. It has been amended in 2015 (2015/863/EU) with the introduction of 4 new substances (DEHP, DBP, BBP, DIBP). This amendment enters into force in two steps depending on the product category (22/07/2019 for cat 1-7, 10, 11 / 22/07/2021 for cat 9, 9i, 8,8i).

Which product does it affect?
All the EEE (electrical and electronic equipment) which fall into the definition:
equipment which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields and designed for use with a voltage rating not exceeding 1 000 volts for alternating current and 1 500 volts for direct current. The same exclusions as defined by RoHS2 are valid.

What is Schneider Electric strategy upon RoHS?
Schneider Electric policy is to comply to RoHS 2015 worldwide and on all product portfolio.

When does it enter in force?
It depends on the product category.
Cat 1-7, 10 & 11: 22 july 2019
Cat 8,8i,9,9i: 22 July 2021

What are RoHS product categories?
RoHS product categories are defined in the Annex I of the directive:
  1. Large household appliances.
  2. Small household appliances.
  3. IT and telecommunications equipment.
  4. Consumer equipment.
  5. Lighting equipment.
  6. Electrical and electronic tools.
  7. Toys, leisure and sports equipment.
  8. Medical devices. (8-8i)
  9. Monitoring and control instruments including industrial monitoring and control instruments. (9-9i)
  10. Automatic dispensers.
  11. Other EEE not covered by any of the categories above.

Where do I check if my product is compliant?
Schneider Electric put in place a "Check your Product" web portal for customers to check the compliance of our products.

What does proactive compliance mean?
Proactive compliance means that the product is in line with RoHS substances restriction even if it is not in the legal scope of the directive.

Which technologies are impacted by the phthalates?
The 4 phthalates which are restricted through RoHS 2015 have been widely used in the past in lots of technologies. SO it's difficult to say that a technology is not impacted; Nevertheless, the most impacted technologies are: soft PVC (polyvinylchlorine) parts & sheets, cables, Elastomers (mainly NBR, Polychloroprene), paints, glues, oils & greases, and related technologies (labels…)

What is Schneider Electric doing to be compliant?
Schneider put in place in 2013 a purchasing platform in charge of supplier data collection for RoHS and REACH declarations. A dedicated database and tool (Crescendo) stores the declarations and allows to assess the compliance at product level. RoHS 2015 requirements are defined in our terms and conditions and shared with our supply chain to ensure compliance of our supplies.

Is Schneider allowed to sell non-compliant products in Europe after the deadline?
No. RoHS is part of CE marking and Schneider cannot put on the market a non-compliant product.

Is Schneider allowed to manufacture non-compliant products after the deadline in European zone?
No. In Europe, Schneider is not allowed to manufacture non-compliant products.

What about non-compliant stocks at distributor, after the deadline?
It is the responsibility of distributor to have a status of his stock and compliance level.
As long as products were on shelf before application date, we can argue that it was compliant at date of purchase of Distributor.

Is the circulation of non-compliant products allowed in Europe after the deadline?
No. It's forbidden.

Are non-compliant spare parts allowed?
Yes, as it is the concept of "repaired as designed", but only in cases where the replaced part is necessary for a properly work of the overall equipment. A product sold compliant after the deadline cannot be repaired with non-compliant spare parts. But a product sold compliant (6 substances) before the deadline can be repaired with non-compliant (4 substances) spare parts.

What is the link between RoHS and CE marking?
RoHS is part of the CE marking. A product in the legal scope of RoHS must be compliant to put the CE marking. A non-compliant product loses the CE marking and cannot be put on the European market.

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