Position paper on the RoHS Directive / ElektroStoffV. Consequences for the building valves industry

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1 Position paper on the RoHS Directive / ElektroStoffV Consequences for the building valves industry Last update: 23/08/2013 Verband Deutscher Maschinenund Anlagenbau e.v. (German Engineering Federation) Professional association Valves Chairman: Dr. Achim Trasser Managing director: Wolfgang Burchard Lyoner Strasse Frankfurt am Main, Germany Telephone Telefax armaturen@vdma.org Internet VDMA Technology for humans

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4 4 VDMA POSITION PAPER RoHS / ElektroStoffV The content has been carefully created and to the best of our knowledge. The VDMA assumes no liability of any kind for possible erroneous or ambiguous representations. Last update: 23/08/2013 VDMA

5 VDMA POSITION PAPER RoHS / ElektroStoffV 3 Content 1. Introduction 6 2. RoHS and ElektroStoffV Background of the ElektroStoffV 2.2 Scopes of application 2.3 Exemptions 3. Large-scale fixed installations Definition of the ElektroStoffV 3.2 Comments of the EU Commission 3.3 Drinking water installation as large-scale fixed installation 4. Summary 11

6 4 VDMA POSITION PAPER RoHS / ElektroStoffV 1. Introduction The revised RoHS Directive a directive for restricting the usage of certain hazardous substances in electrical and electronic equipment has already taken effect as of 21/07/2011. It is superseded by the Electrical and Electronic Substance Regulation (ElektroStoffV) which took effect on 9 May Manufacturers of building valves with electronic components have been asking themselves since that time to what extent their products are affected by the provisions of the regulation. The handling of customer requirements in accordance with an RoHS declaration of conformity also requires clarification. The present position paper explains the central contents of the RoHS Directive and the ElektroStoffV. It describes the scopes of application and the exemptions. The question Are drinking water installatios large-scale fixed installations? assumes a central role in this context. This is because the answer to this question will decide whether the regulation also applies for building valves with electronic components which come into contact with drinking water. Not only the regulations of the ElektroStoffV are important for answering the question. The comments of the EU Commission at the end of 2012 are also significant. The position paper also refers to these comments and explains their relevance with regard to the question.

7 VDMA POSITION PAPER RoHS / ElektroStoffV 5 2. RoHS and ElektroStoffV After it took effect on 21/07/2011, the EU member states were required to nationally implement the revised RoHS Directive by 02/01/2013. This was achieved in Germany by the ElektroStoffV, which was adopted somewhat behind schedule on 19/04/2013 and took effect following its publication in the Federal Law Gazette on 09/05/ Background of the ElektroStoffV The ElektroStoffV applies in general for the launching and provision of new electrical and electronic devices on the market. The former Electrical and Electronic Equipment Act (ElektroG) was amended by Article 1 of the Law on amending the Electrical and Electronic Equipment Act, dated 3 May 2013, and is now exclusively being used for the national implementation of the WEEE Directive (Waste of Electrical and Electronic Equipment). 2.2 Scopes of application According to the ElektroStoffV, electrical and electronic devices from the following categories are affected by its provisions: 1. Large household appliances, 2. Small household appliances, 3. Equipment used in information and telecommunication technology, 4. Consumer electronics equipment, 5. Lighting fixtures, 6. Electrical and electronic tools, 7. Toys and athletic and recreation equipment 8. Medical devices, 9. Monitoring and control instruments, including those used in industry, 10. Automatic output devices, 11. Other electrical and electronic devices not falling under the numbers 1 to 10. In contrast to the Electrical and Electronic Equipment Act, Item 11 is used to introduce an additional equipment category and an open scope of application, which is intended to successively include all electrical and electronic equipment.

8 6 VDMA POSITION PAPER RoHS / ElektroStoffV 2.3 Exeptions According to 1 (2), the regulation does not apply for the following electrical and electronic equipment: 1. Devices required for the essential security interests of the Federal Republic of Germany, including weapons, munitions and defence material for military purposes, 2. Equipment to be used in outer space, 3. Devices which a) are especially designed as a component of another type of device which is either exempted from this regulation or does not fall under the scope of application of this regulation and which are to be installed in this other device. b) can fulfil their function solely as a component of this device and c) can be replaced solely by identical devices, 4. Large-scale stationary industrial tools, 5. Large-scale fixed installations, 6. Modes of transport for passengers or freight with the exception of electrically driven two-wheeled vehicles which are not type-approved, 7. Mobile machines, 8. Active implantable medical devices,

9 VDMA POSITION PAPER RoHS / ElektroStoffV 7 9. Photovoltaic modules designed to be used in a system which was professionally designed, assembled and installed by continuous operation at a fixed location for the generation of electricity from solar radiation energy for public, municipal, commercial, industrial and private applications. 10. Devices which were designed exclusively for purposes of research and development and are provided solely at the inter-company level. 3. Large-scale fixed installations The ElektroStoffV refers to large stationary installations in the list of exemptions. Both the regulation and an accompanying paper of the EU Commission explain the meaning of this. 3.1 Definition of the ElektroStoffV Paragraph 2 of the ElektroStoffV, Art. 3, contains a definition of a large stationary installation : A large-scale arrangement of various types of devices and possibly additional equipment which a) are professionally assembled and installed and b) are intended for permanent operation at a fixed location and are to be dismantled by qualified professionals. The regulation provides additional information on the definition of a large-scale fixed installation in its justification for Art. 3 (Part B for 2, Number 3): Large-scale fixed installations can be found both in industrial, commercial, public (e.g. in hospitals, at the airport) and private/household applications (e.g. residential complexes). Large-scale installations are then considered as fixed if no change of location is planned during the usage phase. ( ) Examples of 'largescale fixed installations' include lifts, luggage conveyors, automated inventory systems, transport systems, and escalators. At the same time, reference is made at this point to a Frequently asked questions document of the European Commission which should clarify additional questions about the definition of a large stationary installation.

10 8 VDMA POSITION PAPER RoHS / ElektroStoffV 3.2 Comments of the EU Commission The document containing additional explanations by the EU Commission was published under the title RoHS-FAQ on 12/12/2012. In accordance with this, a large-scale fixed installation is involved when it is too large when dismantled with all its components to transport in an ISO 20-foot container with the dimensions 5.71 m x 2.35 m x 2.39 m it weighs more than 44 tons when it is dismantled with all of its components and can no longer be transported by truck it must be assembled or dismantled by a heavy-duty crane its output is higher than 375 kw. The EU document includes an additional indicator which speaks for a large-scale fixed installation when it is difficult to determine its size, output and weight: its complexity. It is crucial for this that the installation contain several hundred components which are linked to various subsystems and jointly contribute to the function of the installation. 3.3 Drinking water installation as large-scale fixed installation A drinking water installation fulfils the requirements which apply for a large-scale fixed installation in accordance with 2, Art. 3 of the ElektroStoffV because it is a large-scale arrangement of devices is professionally assembled and installed is intended for permanent operation at a fixed location. In addition to this, it represents a complex system which extends over several stories of a house and can consist of numerous components such as water metres, outlet valves, water softeners, backflow preventers and system separators. Drinking water installations are also components of private and domestic housing complexes, where according to the justification for the ElektroStoffV, large-scale fixed installations can be found.

11 VDMA POSITION PAPER RoHS / ElektroStoffV 9 4. Summary In accordance with the provisions of the ElektroStoffV, 2, Art. 3, a drinking water installation together with its installed building valves is considered to be a large-scale fixed installation. By reason of 1 (2) Art. 5, it is exempted from the scope of application of the regulation. A RoHS declaration of conformity for building valves with electronic components as part of a large-scale fixed installation by means of CE labelling is therefore not possible. Contact partner: Stefan Oberdörfer Fachverband Armaturen im VDMA Frankfurt am Main Tel.: 069 / Fax: 069 / stefan.oberdoerfer@vdma.org