We encourage our customers and partners to review the various environmental regulations affecting electrical and electronic equipment for themselves for a full statement of the legal requirements. If there is any doubt how these regulations may affect your business, take independent legal advice. Keep in mind that regulations may be revised from time to time, so readers should take care to keep themselves informed.
Contents:
Corporate Statement
EEE falling within the categories defined in Annex IA of the WEEE regulations are covered within its scope. Categories include:
1. Large household appliances
2. Small household appliances
3. IT and telecommunications equipment
4. Consumer equipment
5. Lighting equipment
6. Electrical and electronic tools (with the exception of large-scale stationary industrial tools)
7. Toys, leisure and sports equipment
8. Medical devices (with the exception of all implanted and infected products)
9. Monitoring and control instruments
10. Automatic dispensers
DDI has reviewed the typical customer applications for our product against the covered categories and has taken the opinion that categories 8 and 9 may represent many end-user applications in which DDI products are used.
As for DDI products themselves, according to the European Commissions Frequently Asked Questions on RoHS and WEEE directives; “Equipment which is part of another type of equipment is not to be considered a finished product. A finished product is any device or unit of equipment that has a direct function, its own enclosure and - if applicable - ports and connections intended for end users. ‘Direct function’ is defined as any function of a component or a finished product which fulfils the intended use specified by the manufacturer in the instructions for use for an end-user. This function can be available without further adjustment or connections other than simple ones which can be performed by any person.”
DDI considers its product (imaging devices) to be a component that is part of another type of equipment or system (imaging system) as it does not have a direct function outside of this equipment or system. It is this equipment or system, for use by the end user, which must be evaluated to determine if it falls under the scope of the WEEE directive. Therefore the question over applicability of WEEE legislation for a DDI customer’s product must be considered and determined by the customer.
It should be noted that EEE covered by WEEE regulations does not require the use of RoHS compliant components for WEEE compliance.
Related Links
Corporate Statement
EEE falling within Categories 1,2,3,4,5,6,7, and 10 of the WEEE regulations, Annex IA, are covered under the scope of RoHS regulations. Categories include:
1. Large household appliances
2. Small household appliances
3. IT and telecommunications equipment
4. Consumer equipment
5. Lighting equipment
6. Electrical and electronic tools (with the exception of large-scale stationary industrial tools)
7. Toys, leisure and sports equipment
10. Automatic dispensers
DDI has reviewed the typical customer applications for our product against the eight covered categories and has taken the opinion that the vast majority of these applications do not fall within the scope of RoHS. DDI will continue to offer existing non-RoHS compliant products for these applications. DDI will also develop new RoHS compliant products consistent with industry trends. If a customer requires RoHS compliance for its products then they must purchase a suitable RoHS compliant product for use. If compliance is not required they are free to purchase any technically suitable product without the constraints of compliancy.
The two additional categories covered by WEEE not currently covered by RoHS are under consideration by the EU Commission for addition to RoHS regulations, however the timetable has not been finalized. These include:
8. Medical devices (with the exception of all implanted and infected products)
9. Monitoring and control instruments
These categories may represent many end-user applications in which DDI products are used. DDI is developing its RoHS compliant product line in anticipation of this requirement.
According to the European Commissions Frequently Asked Questions on RoHS and WEEE directives; “Equipment which is part of another type of equipment is not to be considered a finished product. A finished product is any device or unit of equipment that has a direct function, its own enclosure and - if applicable - ports and connections intended for end users. ‘Direct function’ is defined as any function of a component or a finished product which fulfils the intended use specified by the manufacturer in the instructions for use for an end-user. This function can be available without further adjustment or connections other than simple ones which can be performed by any person.”
DDI considers its product (imaging devices) to be a component that is part of another type of equipment or system (imaging system) as it does not have a direct function outside of this equipment or system. It is this equipment or system, for use by the end user, which must be evaluated to determine if it falls under the scope of the RoHS directive. Therefore the question over applicability of RoHS legislation for a DDI customer’s product must be considered and determined by the customer.
Related Links:
DDI EU RoHS Compliant Products
It is DDI’s objective to provide our customers with the information they need to plan for, easily identify and document RoHS compliant products. To that end, different product types are in various states of preparedness as we continue our transition.
Product Availability
Consult individual product details for RoHS compliance. If the product you are interested in does not explicitly indicate compliance, please contact your Sales Representative.
Part Number
RoHS compliant products will be identified by the use of an ‘R’ in the part number.
Image capture examples: IL-P3-2048B-R, P3-80-12K40-00-R
Image processing product examples: OR-X4C0-XPF00, CR-GEN0-M6400
Marking
The Pb-free symbol, as shown, will be used to indicate RoHS compliance. The symbol will appear on the product, and associated literature and shipping containers
Compliance Documentation
A downloadable IPC-1752 Material Composition Declaration Form will be available on the respective product pages of the DDI website.
| Marking standard | SJ/T 11364-2006 |
| General Disassembly Requirements | GB/Z xxxx-2006 (Draft) |
| Environment-Friendly Use Period | SJ/Z XXXX-XXXX (Draft) |
| Packing Recycling Mark | GB 18455-2001 |
| Concentration Limits standard | SJ/T 11363-2006 |
| Test Methods standard | SJ/T 11365-2006 |
Corporate Statement
DDI considers its products to fall within the scope of China RoHS Phase 1 therefore all products with the exception of a few specialty items will be produced as compliant.
Implementation
Marking
All DDI products will carry a 20 year Environmental Protection Use Period (EPUP) from date of manufacture. This information will be marked on the product. The operating conditions for which the EPUP applies will be included in the product literature.
Hazardous Substance Data Disclosure
The six substances requiring disclosure will be included in a table in the product literature
Product Literature
A downloadable EIP Disclosure Record is available on the respective product pages of the DDI website (excluding image sensors and ICs). This record will be in both Chinese and English languages.
Packaging Materials
Packaging Materials will be marked directly with the required symbology.
Related Links