EU Directives
The EU Parliament created two Directives intended to reduce certain hazardous substances that may enter the waste stream in Europe. These Directives primarily target consumer products.
The two Directives are the WEEE (Waste Electrical and Electronic Equipment) Directive (2002/96/EC) and the RoHS (Restriction of Hazardous Substances) Directive (2002/95/EC) which took effect July 2006. The Directives are not retroactive and do not apply to products purchased before July 2006, nor do they apply to replacement parts for existing equipment in use before July 2006 (RoHS Article 2, Par 3).
One of the substances being controlled by these Directives is mercury. Mercotac® connectors contain a small amount of liquid elemental mercury. However, because Mercotac® products are used almost exclusively in industrial type machines, they are often exempted in those applications from the scope and restriction by these Directives. See the explanations following.
In the original RoHS directive, "large-scale stationary industrial" equipment, "medical devices" and "monitoring and control instruments" were exempted categories (RoHS Article 2, Par 1)(WEEE Annex 1A/1B, Categories 6, 8 and 9).
The EU Parliament and Council "recast" the RoHS and WEEE directives in 2011 (Directive 2011/65/EU) , effective 21 July 2011. Known as the RoHS2, this revision expanded the scope of electrical products covered by the directives to include almost all electrical and electronic products. However, the original exceptions for "large-scale stationary industrial tools", "medical devices", and "monitoring and control instruments" remained valid (Article 2, Par 4(d) & Article 4, Par 3).
In addition, the Recast included additional exceptions for "large-scale fixed installations" (Article 2, Par 4(e)), "non-road mobile machinery made available exclusively for professional use" (Article 2, Par 4(g)), and "equipment designed solely for the purposes of research and development only made available on a business-to-business basis" (Article 2, Par 4(j)).
The Recast RoHS phased out the exempted categories 8 and 9 so that there are now no exceptions for "medical devices" or "monitoring and control instruments" placed on the market after 22 July 2014 (Article 4, Par 4(b & d)), or "industrial monitoring and control instruments" placed on the market after 22 July 2017 (Article 4, Par 4(e)). Replacements are allowed for products put into service before these dates.
In addition, this Directive linked the CE marking requirement discussed below with the declaration that the EEE equipment is EU compliant, including RoHS and REACH compliance.
Current Legislation
The RoHS2 was amended again by the European Union Parliament in 2017 by Directive (EU) 2017/2102 through which it removed exceptions for almost all mercury-containing products after July 22, 2019. However, this Directive still allows exceptions for large-scale, or stationary, or professionally installed equipment or components of same (Article 2, Par 4). Click here to see guidance about the RoHS2, including definitions of "large-scale" exceptions Q3.1. Repair and replacements for equipment on the market before July 22, 2019 are excluded from restrictions per an addition to RoHS2 (2011) Article 4, Paragraph 4 by the 2017 amendment.
The European Union has also passed Regulation 2017/852 which implements the United Nations Environment Programme's (UNEP) Minamata Convention on Mercury of 2013. The EU regulation bans many mercury-containing products specifically listed in Article 5 and Annex II after 2020. The EU Regulation also includes a ban on new mercury-containing products after January 1, 2018 (Article 8, Par 1). Mercotac's rotating electrical connectors are not new products and are not listed within the scope of either the EU Regulation 2017/852 nor of the UNEP Minamata Convention (see the Minamata Convention covered products: Annex A, Part 1 list for Article 4, Par. 1).
Specific laws implementing the UNEP and EU regulations must be passed by individual countries (signatory members) to take effect and be binding. Specific country laws and enforcement should be researched by the machine manufacturer or importer. It is known that Norway, Denmark and Sweden have stricter bans on mercury-containing products than these EU Directives and other EU member states.
CE Mark for Europe
The WEEE and RoHS Directives now also require affixing a "CE" mark to products and machinery to indicate that "the product is in conformity with the applicable requirements set out in Union harmonisation legislation" (2011/65/EU, Article 14). However, Mercotac® connectors contain elemental mercury, and even though they may be excepted from the scope of the EU directives for most applications (that is, for equipment that is large-scale industrial, stationary, and/or professionally installed), they still cannot be said to conform to the RoHS Directives. Also, Mercotac® products are considered "passive components" to be incorporated into other electrical equipment and for which there are no specific electrical safety standards. Therefore, according to the EU Low Voltage Directive 2014/35/EU (recast of previous LVD 2006/95/EC), Mercotac® connectors can only be CE marked by the machine manufacturer based upon that particular application and electrical specifications. See the "Low Voltage Directive 2014/35/EC Guidelines", page 20, section 7 & footnote 11.
REACH In Europe
On 1 June 2007, European Union Regulation (EC) No. 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals ("REACH" for short) came into force. REACH specifies under Article 33 that manufactured "articles" require Safety Data Sheets only when the articles contain a Substance of Very High Concern (SVHC) or are intended to release a hazardous substance under normal use or disposal. The candidate list of 15 SVHC published on 28 October 2008 has been added to over the years to now include over 201 REACH substances.
Mercotac® rotating electrical connectors are manufactured articles, not chemicals, and are not intended to release any substance under normal or reasonably foreseeable conditions of use or proper disposal. According to our current knowledge, no SVHC substances from the candidate list are present in our products. Therefore, no Safety Data Sheets are required for Mercotac® products under the REACH regulations. However, an MSDS or SDS for elemental mercury is available upon request.
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