Impact assessment of introduction of a general scope of the RoHS Directive – selected aspects

Table 3.1
List of product groups considered by the authors to fall within the categories in Annex I
Category Product group Remarks Product examples (as of the day
accessed)
Within the scope of the Danish RoHS Regulation CN codes
1. Large household appliances Awnings and sunblinds   http://viking-markiser.dk/con8.php4 icon 6306 1100, 6306 1200, 6306 1100 : Tarpaulins, awnings and sun-blinds
Towel radiators May be included in Category 1 under "electric heaters"
but the "electric heaters" are mentioned as examples
("such as") under the product group "Large appliances
for heating rooms, beds, seating furniture, such as…"
These heaters consequently only include the three
listed applications.
Some of the heaters may be considered part of a fixed
installation but smaller units are sold as finished
products in line with other electric heating appliances.
http://www.midtjysk-vvs.dk/product.asp?
product=4337
icon Included in aggregated
commodity group, probably:
85167970 Electro-thermic
appliances, for domestic
use (excl. …)
Mirror heaters/mirrors with heating http://www.elvvs.dk/articlelist.3390 icon
Electric water heaters http://dk.ivt.se/products.asp?
lngID=481&lngLangID=1
icon 85161011 Electric instantaneous water heaters
85161019 Electric water heaters (excl. instantaneous water heaters and immersion heaters)
Centrifuges May be considered included in "Clothes dryers". The Danish translation, however, use the wording "tørretumblere" which obviously does not include centrifuges http://laundrysystems.electrolux.dk/
node351.aspx?categoryid=59
icon 84211200 Centrifugal clothes-dryers
Greenhouse heaters Heaters for greenhouses and garden frames based on heating cables in the soil http://herbngardens.com icon Included in aggregated commodity group
Aquaria heaters Aquaria heaters are in fact quite small, but are in their use most similar to products within this category   ÷ Probably included in:
85161019 Electric water heaters (excl. instantaneous water heaters and immersion heaters)
Power showers, whirlpools, saunas and similar equipment The equipment range from power showers which is a stand alone appliance to whirlpools that may be considered part of a fixed installation. The delineation between a finished product and a fixed installation is not clear-cut. http://www.victorianbathrooms4u.com/
Showers.488/Electric
+Showers.451/
ABSTRACT.53/Shower-5187%7C/
Aqua+G1000+Manual+
Power+Shower+(5187).5187.html#
÷ Included in aggregated commodity group
Gas cookers with digital clocks     ÷ Included in aggregated commodity group
Electric door openers     ÷ Included in aggregated commodity group
Electric window openers     icon Included in aggregated commodity group
2. Small household appliances Baking machines   http://www.bagemaskinen.dk/?gclid=
CKTT8aTcqpwCFZ0U4wodv0dJlA
icon Included in 73211900 Appliances for baking, frying, grilling and cooking and plate warmers, for domestic use, of iron or steel, for solid fuel or other source of energy (excl. liquid or gaseous fuel, and large cooking appliances)
Electrical portable cooling boxes May in principle be included under Category 1, but this category includes only "large cooling appliances". The wording indicates that small cooling appliances are not included http://www.nordiskcampingudstyr.dk/shop/
koelebokse
-68c1.html
icon Included in aggregated commodity group
Immersion boilers and heaters   http://www.frederiksen.eu/da/produkter/
_dk_fysik_
varme_144/kalorimeter
-varmeenergi/vnr/275020/
icon 85161091 Electric immersion heaters of a kind used for domestic purposes
Rice boilers     icon Included in aggregated commodity group
Egg boilers     icon Included in aggregated commodity group
Deep fat boilers     icon 85167920 Electric deep fat fryers, for domestic use
Electric kettles     icon 85161019 Electric water heaters (excl. instantaneous water heaters and immersion heaters)
Popcorn machines     icon Included in aggregated commodity group
Electric pasta machines   http://www.galttech.com/research/household-
DIY-tools/best-pasta-maker-machine.php
icon Private use: Included in aggregated commodity group
Professional use: 84381090 Machinery for the industrial preparation or manufacture of macaroni, spaghetti or similar products (excl. macaroni drying machines and dough rollers).
Ice cream makers   http://www.coffeeitalia.co.uk/proddetail.php?
prod=gicmg&gclid=
CKuHyeDtvpwCFZMU4wodTAFloQ
icon Probably included in 84186900 Refrigerating or freezing equipment (excl. refrigerating and freezing furniture)
Food processors and dough-mixing machines   http://www.valdemarsro.dk/?p=1218 icon 85094000 Domestic food grinders and mixers and fruit or vegetable juice extractors, with self-contained electric motor
Blenders and juice extractors     icon
Waffle irons     icon Included in aggregated commodity group
Fly traps Fly trap both exist as small units for households and large units e.g. used in agriculture http://www.chrisal.dk/insekter.htm ÷ Included in aggregated commodity group
Distillation units Small equipment for distillation in households http://www.easystill.com/ icon Included in 8419 40 00 Equipment for distillation or rectification
Electric potato peeler   http://www.el-handel.dk/product.asp?
product=2076
icon Included in aggregated commodity group
Electric lighter   http://www.tootoo.com/d-p11642227-BBQ_
Kitchen_Gas_Electric_Lighter/
÷ 96132010 Pocket lighters, gas fuelled, refillable, with electrical ignition system
Electric blankets   http://www.cpsc.gov/cpscpub/prerel/prhtml03/
03114.html
÷ Included in aggregated commodity group
Electric foot baths Equipment for the purpose of spreading light is included in Category 5, but this category is considered not to include equipment for which the light is a secondary purpose http://www.chem1.com/CQ/FootBathBunk.html ÷ Included in aggregated commodity group
Shower heads with light http://www.coolstuff.dk/Lysende_brusehoved ÷ Included in aggregated commodity group
Makeup mirrors with light   ÷ Included in 70099200 Glass mirrors, framed (excl. ….)
3. IT and telecommunications equipment   USB memory sticks have been mentioned as outside the scope, but both USB sticks and tapes (for a tape recorder) are equipment for the storage of information and dependent on electric currents or electromagnetic fields in order to work properly (in order to communicate the information) – thereby they fall in this category.
Radio Frequency Identification (RFID) chips have been mentioned as possibly outside the scope, but the chips must be considered equipment for the storage of information and dependent on electric currents or electromagnetic fields in order to work properly (in order to communicate the information) – thereby they fall in this category.
     
4. Consumer equipment   General comment: In the interpretation of Category 4 it is assumed that the second "including" in the Commission’s proposal is a mistake, otherwise the category should only cover "signals or other technologies for the distribution of sound and image than by telecommunications..".      
5. Lighting equipment   Different equipment with build-in light, where the light emission is not the primary property, is listed elsewhere. Solariums may be considered as being outside the scope, because the primary purpose is the tanning. However, the category includes all equipment for spreading light, irrespective of the purpose of spreading the light (illumination, tanning, disinfection, heating).      
6. Electrical and electronic tools (with the exception of large-scale stationary industrial tools) Mixing machines used in construction industry and in industry Mixing of concrete and mortar cannot be considered "similar processes" to the processes listed   icon 84743100 Concrete or mortar mixers (excl. those mounted on railway wagons or lorry chassis)
84743200 Machines for mixing mineral substances with bitumen [probably large-scale industrial tool]
Concrete vibrators Vibrating of wet concrete or surfaces cannot be considered "similar processes" to the processes listed http://www.city-rentals.ca/
rental_equipments.php?
catId=4
icon Included in aggregated commodity group
Kilns Examples are small kilns use for ceramics in households and institutions. Ovens used in laboratories included in "laboratory equipment" mentioned below.   ÷ Included in aggregated commodity group
Electric lifts Lifts e.g. used in health care sector or pallet lifts http://www.liftrite.dk/let1300.htm ÷ Included in 84281020 Lifts and skip hoists, electrically operated
Electric car jacks   http://www.harald-nyborg.dk/merinfo.asp?
varenr=5018&n=60100
÷ Large stationary types included in: 84254100 Built-in jacking systems of a type used in garages
Electric wire rope winches   http://www.liftket.de/index.php3?WRW?lang=en ÷ 4251100 Pulley tackle and hoists, powered by electric motor (other than skip hoists or hoists of a kind used for raising vehicles)
Electrical binding machines E.g. used in offices for binding reports http://www.tegneogkontor.dk/shop/
elektrisk
-indb-maskine-3770p.html
÷ Included in 8440 Machines for bookbinding incl. book-sewing machines
Electric ladders   http://www.atticconversioncentre.com.au/
ladders.html
÷ Included in aggregated commodity group
7. Toys, leisure and sports equipment Other toys with EE components Examples are:
- electric cash register
- talking dolls, animals and robots
- electric cars for driving
- scooters with flashing light
- electric space shuttle set
- dancing cow
- whistles with light
-pens with light
-books with light or sound
  icon Included in aggregated commodity groups
Electronic greeting cards     ÷ Included in aggregated commodity group
Adult erotic toys with EE components     ÷ Included in aggregated commodity group
Fun and joke equipment with EE components Examples are exploding matches, pen with electric shock, lighter with electric shock   ÷ Included in aggregated commodity group
Ornaments and fine arts with EE components Examples are rotating angels or Christmas trees http://www.treetopia.com-artificial-
christmas-trees-p/rotating-christmas-
tree.htm
÷ Included in aggregated commodity group
Other amusement machines including mobile amusement park equipment It is not clear how much is covered by the term "coin slot machines". In the Danish version of the Commission’s proposal it is translated to "møntautomat", meaning a "coin operated machine" which is rather under "automatic dispensers" than "Toys, leisure and sports equipment".
"Coin slot machine" is often used as synonymous for gambling machines and is the same as "Geldspielautomaten", used the German translation. In Danish this corresponds to a "spilleautomat".
If this is the meaning a number of other amusement machines e.g. "flipper machines" or electrical rocking toys (e.g. a Postman Pat car) are not included. The delineation between small amusement machines and fixed installations is not clear, as some large-scale equipment, resembling stationary equipment in amusement parks is actually mobile units.
The wording "coin slot" would further exclude all equipment where other payment methods than inserting a coin are applied.
  icon 9504 Articles for funfair, table or parlour games, including pintables, billiards, special tables for casino games and automatic bowling alley equipment
8. Medical devises   See Veterinary devices below
A number of different devices used in medical centres, but not used for human beings are included in laboratory equipment mentioned above
     
9. Monitoring and control instruments All measuring, weighing or adjusting appliances used in offices, agriculture, artisanal workshops and institutions Category 9 includes only appliances used in households, laboratories and industry. Equipment used in all other settings are not included   ÷ Many different commodity groups - not specified on where the equipment is used
Baby alarms May alternatively fall between Category 3 and Category 4 as it is both equipment for recording and telecommunications   ÷ Included in aggregated commodity group
Closed-circuit Television(CCTV) CCTV, used for video surveillance, is currently considered as being category 9 equipment in some countries (UK, Germany); whereas it is considered as being part of Category 4 equipment in other countries (Belgium, the Netherlands) (Bogaert et al., 2008).
If CCTV is considered to be included in Category 9 "monitoring and control instruments" it is only in industrial setting. The main part of the surveillance equipment will thus be out of scope of the Directive.
Alternatively, the equipment, like the baby alarms, may fall somewhere between Category 3 and Category 4. As category 4 includes consumer equipment it is not obvious that equipment used commercially falls within the category.
  icon Included in aggregated commodity group
Fire alarms The specific inclusion of "Smoke detectors" in the list indicates that detectors and alarms are not considered to be included in measuring appliances. Fire alarms and burglar alarms may be considered part of fixed installations, but some types of burglar are used as single units - just like smoke alarms. http://www.avotex.net/producten.htm
#Autonoom%20brandalarm,%20Type%204
÷ 8531 10 Burglar or fire alarms and similar apparatus
Burglar alarms   ÷
Water Flow Detectors Detectors used for monitoring water flow in houses. In line with heating regulators and thermostats. May as well as heating regulators and thermostats be considered a part of fixed installations.   ÷ Included in aggregated commodity group
10. Automatic dispensers Payment terminals Terminals for payment e.g. for parking do not dispense a product and may be considered not to fall within the category   ÷ Included in aggregated commodity group

 



Version 1.0 April 2010, © Danish Environmental Protection Agency