Are You Ready? WEEE Directive Full Implementation Starts 15-Aug-18

Many man­u­fac­tur­ers selling indus­tri­al products into the EU mar­ket have come to under­stand at least one of the envir­on­ment­al pro­tec­tion Dir­ect­ives, RoHS – the “Restric­tion of the Use of Cer­tain Haz­ard­ous Sub­stances.” In this post, I’m going to be look­ing at anoth­er envir­on­ment­al dir­ect­ive: WEEE – the “Waste Elec­tric­al and Elec­tron­ic Equip­ment” Dir­ect­ive (2012/19/EU).

As of 14 August 2018...ALL waste electrical and electronic equipment comes under the directive.


The WEEE Dir­ect­ive requires pro­du­cers of elec­tric­al and elec­tron­ic equip­ment who sell their products in the EU to oper­ate a recyc­ling pro­gram. This dir­ect­ive exemp­ted indus­tri­al products in the first years of its imple­ment­a­tion, focus­ing primar­ily on waste con­sumer elec­tron­ics and elec­tric­al equip­ment. As of 14 August 2018, the trans­ition peri­od ends and ALL waste elec­tric­al and elec­tron­ic equip­ment (EEE) comes under the dir­ect­ive, except those spe­cif­ic classes exemp­ted in Art­icles 3 & 4.  How does this affect machine build­ers and man­u­fac­tur­ers of oth­er kinds of products? Read on for the answer to these ques­tions and more. 

Con­tin­ue read­ing “Are You Ready? WEEE Dir­ect­ive Full Imple­ment­a­tion Starts 15-Aug-18″

CE, Brexit, and Authorised Representatives

CE, Brexit and Authorised Representatives

We’re just passing the T-1 year mark on the UK’s jour­ney towards leav­ing the EU. Some of my read­ers are “Leav­ers”, while oth­ers are “Remain­ers”, but for every­one liv­ing in the UK or doing busi­ness with the UK, there are many ques­tions that remain unclear. To be fair, some of the lack of clar­ity is due to the nego­ti­ation pro­cess that Prime Min­is­ter May’s gov­ern­ment is engaged in, and some of it is the res­ult of the com­plex­ity in the EU-UK rela­tion­ship. I hope to add some clar­ity to this situ­ation, at least as far as the impact on third-coun­try man­u­fac­tur­ers and CE Mark­ing is con­cerned.

What is an Authorised Representative?

Wheth­er or not a man­u­fac­turer is based in the EU, they may use an Author­ised Rep­res­ent­at­ive to carry out cer­tain tasks, such as [1, 3.2]:

  • keep­ing the EU declar­a­tion of con­form­ity and the tech­nic­al doc­u­ment­a­tion at the dis­pos­al of nation­al sur­veil­lance author­it­ies and coöper­ate with them at their request,
  • provid­ing that Nation­al Author­it­ies with all the inform­a­tion and doc­u­ment­a­tion neces­sary to demon­strate the con­form­ity of a product,
  • tak­ing actions to elim­in­ate the risks posed by products covered by their man­date,
  • affix the CE mark­ing and noti­fied body’s num­ber to the product,
  • draw up and sign the EU declar­a­tion of con­form­ity.

Man­u­fac­tur­ers loc­ated out­side the EU may be obliged to have an Author­ised Rep­res­ent­at­ive by the Dir­ect­ives applic­able to their products. Com­mer­cial rep­res­ent­at­ives such as author­ised dis­trib­ut­ors or agents, should not be con­fused with the “author­ised rep­res­ent­at­ive” in the mean­ing of Uni­on har­mon­isa­tion legis­la­tion.

Hav­ing an Author­ised Rep­res­ent­at­ive entails spe­cif­ic con­trac­tu­al oblig­a­tions. The EU Blue Guide [1] can help you to under­stand those oblig­a­tions and the pro­vi­sions that are rel­ev­ant to the agree­ment. Since I am not a law­yer, I can’t provide you with spe­cif­ic leg­al advice on this top­ic but an EU con­tracts law­yer can help you with the neces­sary arrange­ments. Many of the organ­iz­a­tions that have been provid­ing these ser­vices for many years have ready-made con­tracts that ful­fil the require­ments and can get you set-up quickly.

How will Brexit affect your CE Mark?

Since the UK joined the European Eco­nom­ic Com­munity (EEC) on 1-Jan-1973 [2], [3], [4], the rela­tion­ship has become a com­plex one, and dis­en­tangling this rela­tion­ship is going to take some time.

On the sur­face, third-coun­try man­u­fac­tur­ers are not required to have an EU-based Author­ised Rep­res­ent­at­ive [1], how­ever, some CE Mark­ing Dir­ect­ives include expli­cit require­ments regard­ing Author­ised Rep­res­ent­at­ives, while oth­ers like the Machinery Dir­ect­ive, have impli­cit require­ments that res­ult in third coun­try man­u­fac­tur­ers need to have an Author­ised Rep­res­ent­at­ive based in the EU.

If you have a con­tract with an Author­ised Rep­res­ent­at­ive cur­rently based in the UK, your CE Mark will no longer be val­id on 1-Apr-2019 unless you make oth­er arrange­ments [5].

How will Brexit affect my Authorised Representative?

Since the UK and North­ern Ire­land will be leav­ing the EU at the end of March, 2019, any organ­iz­a­tion that offers Author­ised Rep­res­ent­at­ive ser­vices will no longer be able to meet the require­ment for being based in the EU. Where an indi­vidu­al is act­ing as an Author­ised Rep­res­ent­at­ive, they have the option to move from the UK to any oth­er EU Mem­ber State before the UK offi­cially exits the uni­on. Where an organ­iz­a­tion is provid­ing an Author­ised Rep­res­ent­at­ive ser­vice, they have the option to move their cor­por­ate headquar­ters to any oth­er EU Mem­ber mem­ber state. Once they can show that they are based in an EU coun­try, then they can legit­im­ately offer Author­ised Rep­res­ent­at­ive ser­vices again.

Need help with CE Mark­ing? I can help! Con­tact me at +1 (519) 650‑4753 or by email.

References

[1]     European Com­mis­sion, “Com­mis­sion Notice — The ‘Blue Guide’ on the imple­ment­a­tion of EU products rules 2016″, Pub­lic­a­tions Office of the European Uni­on, Lux­em­bourg, 2018.

[2]     “When did Bri­tain decide to join the European Uni­on? – UK in a chan­ging Europe”, Ukandeu.ac.uk, 2018. [Online]. Avail­able: http://ukandeu.ac.uk/fact-figures/when-did-britain-decide-to-join-the-european-union/. [Accessed: 30- Mar- 2018].

[3]     “BBC News – A timeline of the EU”, News.bbc.co.uk, 2018. [Online]. Avail­able: http://news.bbc.co.uk/2/hi/europe/3583801.stm. [Accessed: 30- Mar- 2018].

[4]     European Com­mis­sion, “Com­mis­sion Notice — The ‘Blue Guide’ on the imple­ment­a­tion of EU products rules 2016″, Pub­lic­a­tions Office of the European Uni­on, Lux­em­bourg, 2016.

[5]     DIRECTORATE-GENERAL FOR INTERNAL MARKET, INDUSTRY, ENTREPRENEURSHIP AND SMEs, “NOTICE TO STAKEHOLDERS — WITHDRAWAL OF THE UNITED KINGDOM AND EU RULES IN THE FIELD OF INDUSTRIAL PRODUCTS”, European Com­mis­sion, Brus­sels, 2018.

New Directions in Plastics Machinery

Canada’s Participation in ISO TC 270

SCC Standards Council of Canada LogoIn Feb­ru­ary of 2016, Canada formed the SCC Mir­ror Com­mit­tee (SMC) to ISO TC 270, Rub­ber and Plastics Machinery. This inter­na­tion­al tech­nic­al com­mit­tee is cur­rently devel­op­ing ISO 20430, the first inter­na­tion­al plastic injec­tion mould­ing machine stand­ard. Until the pub­lic­a­tion of ISO 20430, two stand­ards have been fight­ing for dom­in­ance: EN 201, Plastics and rub­ber machines — Injec­tion mould­ing machines — Safety require­ments, and ANSI B151.1, Amer­ic­an Nation­al Stand­ard for Plastics Machinery – Hori­zont­al Injec­tion Mould­ing Machines – Safety Require­ments for man­u­fac­ture, Care and Use.

Canada has a strong plastic and rub­ber industry, with key equip­ment man­u­fac­tur­ers like Athena Auto­ma­tion, Husky Injec­tion Mold­ing Sys­tems, Mold Mas­ters and GN Plastics among oth­ers pro­du­cing world class machinery for the industry. The industry is rep­res­en­ted nation­ally by the Cana­dian Plastics Industry Asso­ci­ation. Des­pite this, Canada has nev­er had its own stand­ard for this type of machinery.

Involve­ment in ISO TC 270 allows Canada’s plastics industry to have a voice in devel­op­ing the inter­na­tion­al stand­ards for the machinery they design and build, and which ever more com­monly, they buy and use.

The com­mit­tee needs your help to know which way Cana­dian industry wants us to focus our efforts as the work on ISO 20430 wraps up in com­ing months. We have a short sur­vey, just three ques­tions long, where you can rank five pos­sible top­ics we can focus on. We will be sub­mit­ting our com­mit­tee vote in early August on the top­ic, so you have a month or so to answer the ques­tion­naire. Let us know your pref­er­ences.

Why now?

ISO LogoUntil the pub­lic­a­tion of ISO 20430, two stand­ards have been fight­ing for dom­in­ance: EN 201 in Europe, and ANSI B151.1 in North Amer­ica. Until the rel­at­ively recent form­a­tion of ISO TC 270 in 2012, there were NO inter­na­tion­al stand­ards for this type of machinery. While there have been some efforts to har­mon­ise the European and ANSI stand­ards, there are still some sig­ni­fic­ant gaps between these stand­ards. In addi­tion, ANSI’s B151 com­mit­tee has a num­ber of addi­tion­al stand­ards for aux­il­i­ary equip­ment for items like robots designed to unload molds, that are not dir­ectly addressed in EN stand­ards.

Canada was giv­en a chance to par­ti­cip­ate through our ongo­ing friend­ship with ANSI and the USA, so between 2012 and 2015, Cana­dian del­eg­ates atten­ded ISO TC 270 work­ing group meet­ings inform­ally, and put Canada’s per­spect­ive for­ward through the US ANSI TAG com­mit­tee, but in 2016 it became clear that we needed to form our own com­mit­tee. If you are involved in the industry and you are a mem­ber of one of these gen­er­al groups and would like to get involved with stand­ards devel­op­ment, please go to our recruit­ing page and join us!

Committee Membership Matrix

Mat­rix Cat­egory Min Max Cur­rent
Total  15  25  6
Pro­du­cer Interest (PI) 3 5 3
User Interest, Man­age­ment (UM) 3 5 1
User Interest, Labour (UL) 3 5 0
Reg­u­lat­ory Author­ity (RA) 3 5 1
Gen­er­al Interest (GI) 3 5 1

As you can see from the table, we need mem­bers in every group except the pro­du­cers to meet our inten­ded bal­ance.

Definitions of the Categories

Pro­du­cer Interest (PI) — Machine build­ers, Aux­il­i­ary Equip­ment Man­u­fac­tur­ers, Con­sult­ants, and Engin­eer­ing Com­pan­ies provid­ing for-profit ser­vices related to plastics and rub­ber machinery.

User Interest, Labour (UL) — Cana­dian labour uni­ons, labour organ­iz­a­tions, and indi­vidu­al work­ers loc­ated at Cana­dian work­places.

User Interest, Man­age­ment (UM) — Trade asso­ci­ations, com­pan­ies, con­tract­ors, and organ­iz­a­tions rep­res­ent­ing com­pan­ies engaged in work per­formed in Canada.

Reg­u­lat­ory Author­it­ies (RA) — OHS pro­vin­cial and fed­er­al reg­u­lat­ory bod­ies (labour and elec­tric­al).

Gen­er­al Interest (GI) — Safety asso­ci­ations, research organ­iz­a­tions, insti­tu­tions, and non-com­mer­cial con­sult­ants who have expert­ise in the sub­ject area.

We need your help!

CAC ISO TC 270 needs your help!

Can you volun­teer some time? Sign up!

Can you help dir­ect us? Answer our ques­tion­naire!

Need more inform­a­tion? Con­tact Doug Nix!