Directive 2002/95/EC restricts the use of lead, cadmium, hexavalent chromium, mercury and polybrominated biphenyls (PBB) and polybrominated diphenylethers (PBDE) for electrical and electronic equipment put on the market since 1st July 2006.
The Recast RoHS Directive 2011/65/EU maintains these restrictions and extends them to medical devices (category 8) and monitoring and control instruments (category 9). The recast also introduces a new category 11 that includes all Electrical and Electronic Equipment not covered by any of the other 10 categories in the scope of the Recast RoHS Directive after a period of 8 years. In addition, the Recast RoHS Directive outlines a methodology for reviewing the existing substance restrictions and for introducing new restrictions as required.
With regard to PennEngineering® fastener product compliance, nothing changes as a result of these Recast initiatives. The same six substances and same threshold limits for each still apply.
The expansion of the industry scope however will require RoHS compliance for a portion of our customer base not previoulsy affected. In particular those companies manufacturing medical devices and monitoring and control instruments.
The recast also includes CE marking requirements. However, we do not need to mark fasteners, as they are not an item included in Annex I. The CE marking requirement also establishes certain minimum requirements for the systems used by component suppliers to document RoHS compliance. PennEngineering is currently investigating this requirement and will comply as required.