Table/Figure – Environmental Project No. 1316 2010 – Impact assessment of introduction of a general scope of the RoHS Directive

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

Table 3.2
List of product groups considered by the authors to fall outside the scope of the categories in Annex I, nor specifically be designed for military applications, transport equipment, aerospace applications, fixed installations or large-scale stationary industrial tools.
Category	Product group	Remarks	Product examples	Considered within the scope of the Danish RoHS Regulation	Commodity codes
Veterinary devices	Much of the equipment used for medical applications may be used for veterinary applications: vital sign monitors, defibrillators, electro surgical generators, infusion pumps, etc.	Category 8 includes equipment within the scope of 93/42/EEC and 98/79/EC. Both directives address equipment for human beings only. Some equipment used in veterinary clinics may be included in other products categories, but a range of products are not.	Examples can be found at http://www.dreveterinary.com	÷	Included in aggregated commodity groups - same commodity groups as medical devices
Other laboratory equipment	Such as, ultrasonic cleaners, mixers, ovens, fume hoods, distillation equipment, sterilisation equipment, heating equipment, etc.	It is a question whether this equipment would fall under category 6. Some equipment may be covered by some of the product groups under household appliances although not used in households. It is certainly not included in Category 9 as the equipment is not used for measuring and control.		÷	Partly covered by: 84192000 Medical, surgical or laboratory sterilizers 84211920 Centrifuges of a kind used in laboratories
Equipment for generation, transmission or conversion of electricity	Extension cords			÷	Included in aggregated commodity group
	Transformers	Transformers are sometime sold as separate units to be optionally used together with equipment falling within the categories in Annex I. An example is a transformer marketed for use with an I-pod, but usually not sold together with the I-pod		÷	Probably included in 8515 39 13 Transformers which is a broad group of transformers
	Battery chargers			÷	8504 40 55 Accumulator chargers
	Portable generators	May be considered a tool for generation of electricity and consequently within the scope of Category 4. All mentioned tools are however used for shaping or changing materials and generation of electricity is a totally different application		÷	Specific codes included in 8502 Electric generating sets and rotary converters 8501 61 - 8501 64 Alternators
	UPS (uninterruptable power supply)	UPS units are used as back-up power supply. The major part of UPS units is relatively large and can be considered part of a fixed installation. Small units used for households, e.g. as power backup for a single computer, are marketed as finished products.	http://www.elitedgeelectronics.com/ catalog/index.php?main_page= index&cPath=6_84	÷
	Photovoltaic cells and panels	Examples are solar panels for producing electricity for a pump for a garden pond. Small solar panels may be integrated in different kind of equipment e.g. garden lamps or calculators, but are in these cases covered if the equipment falls within one of the existing categories. Large solar panels are considered to be part of fixed installations.		÷	Included in aggregated commodity group
Clothing and footwear with EE components	Caps with light	Clothing and footwear with EE components may be considered similar to the product group "Sports equipment with electric or electronic components" in Category 7.		÷	Included in aggregated commodity group
	T-shirts and other clothing with light		http://www.coolstuff.dk/WiFi_T-shirt	÷	Included in aggregated commodity group
	Shoes with light			÷	Included in aggregated commodity group
Consumables with EE components	Cartridges for printers with EE components	May be considered a spare part for a printer, as the printer would not function without the cartridge, however, in the FAQ for the existing RoHS Directive (EC, 2006) the Commission consider ink cartridges to be out of the scope of the RoHS Directive Some cartridges have electronic components and are themselves dependent on an electric current in order to work properly		÷	Included in aggregated commodity group
Consumables with EE components	Consumables for measuring equipment such as electron capture detectors, electron multipliers, laser tubes, electrodes, valves and UV-lamps	Cartridges for printers (mentioned above) are according to Test & Measurement Coalition estimated to be 5,000 times greater in volume than all category 9 industrial consumables combined (TMC, 2009). An example of a consumable for measuring equipment that represent a significant quantity of mercury use is hanging drop electrodes used in polarography.		÷	Included in aggregated commodity group
Furniture with EE components	Airbeds with electrical pump			÷	6306 40 00 Airbeds
	Elevation tables			÷	Included in aggregated commodity group
	Elevation beds	Beds with electrical moveable parts not used in the medical sector. Hospital beds are considered medical devices.		÷	Included in aggregated commodity group
	Chairs with electric moveable parts	Includes chairs used in households. Chairs used in dental clinics may be considered medical devices		÷	Included in aggregated commodity group
	Cupboard and other furniture with electric light	Cupboards e.g. in kitchens often have integrated light		÷	Included in aggregated commodity group
Other products with EE components	Microscopes and magnifying glass with light	Includes equipment for optical image processing including also equipment for reading f microfilms. The equipment does not fall within Category 4 as the equipment is not reproducing the images. Electron microscopes falls within Category 3		÷	9011 Compound optical microscopes, including those for photomicrography, cinephotomicrography or microprojection
	Key finders			÷	Included in aggregated commodity group
	Electronic keys			÷	Included in aggregated commodity group
	Incubators and incubation chambers	An example is incubators for hatching egg (includes a thermostat, but is not itself a thermostat)	http://www.eggincubators.co.uk/	÷	Partly covered by 8436 21 00 Poultry incubators and brooders
	Strongboxes and safes with electronic lock	Examples are safes in hotel rooms or baggage boxes in train stations – some may be considered part of fixed installations		÷	Included in 8303 00 Armoured or reinforced safes, strongboxes and doors and safe deposit lockers for strongrooms, cash or deed boxes and the like, of base metal
	Patient simulators	Cat. 8 “medical devices” includes devices to be used for human beings”. The patient simulator is not exactly used for human beings and may not be included.		÷