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TURA Continuing Education Conference – Global Toxics Policy Update (Session E) (Surprising) Lessons Learned while meeting RoHS 2 CE Marking Requirements

November 2014 Raymond Lizotte Director, SEIT Environmental Stewardship Office

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Agenda

> Schneider Electric > RoHS 2 Lessons Learned

> Blue Guide > Essential vs. CE Marking Requirements > Basic requirements because of CE Marking Requirements > Surprising impact on the regulated community

> Conclusions

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Schneider Electric – focusing on energy

Energy is key to our business – from generation to use….

72% of energy consumption Integrated solutions where energy is used…

24 billion € sales in 2013

41% of sales in new economies

140,000 people in 100 countries

4-5% of sales devoted to R&D

Schneider Electric Business Overview

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SE-IT (APC) Business Overview

Worldwide

Business Description

Segment Responsibility $4.6B UPS Services

Cooling Racks/PDUs Software

#1 #1 or #2 #3 #1 or #2 #2

2013 annual sales

Finance Cloud/Collocation IT

Surge Protectors Industrial UPSs Home & Professional UPSs Data Centers

Link to SE Business

Cooling Software Security

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CE Marking Directive

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● http://ec.europa.eu/enterprise/policies/single-market-goods/documents/internal-market-for-products/new-legislative-framework/index_en.htm

http://ec.europa.eu/enterprise/policies/single-market-goods/documents/internal-market-for-products/new-legislative-framework/index_en.htmhttp://ec.europa.eu/enterprise/policies/single-market-goods/documents/internal-market-for-products/new-legislative-framework/index_en.htm

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Blue Guide on the implementation of EU product rules 2014

> Provides guidance on achieving conformance with Directives, including RoHS2.

and 18 other directives.

http://ec.europa.eu/DocsRoom/documents/4942/attachments/1/translations/en/renditions/native

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RoHS2 – Essential vs. CE Marking Requirements

In Scope Product

Electronic Part

Accessory

Mechanical Part

Battery

Subject to Essential Requirements

Subject to CE Marking Requirements

YES

NO

NO

Maybe (when the accessory is an In Scope product)

Maybe, but not for RoHS 2

Only products listed as subject to CE Marking Directive are authorized to carry CE Mark. Misuse of CE Mark is a violation!

Subject to essential requirements of Battery Directive

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Changes to product marking

> Telephone numbers, web URL, non-EU address not acceptable.

> Requires EU street address.

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Documentation

> CE Declaration of Conformity > Available in Native Languages > Make available to distributors,

customs agents, regulators as a condition of market entry.

> Technical File > Make available to regulators

within 15 days of request.

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● Ten (10) AP9624 shipped from U.S. manufacturer in U.S. to European customer were stopped by customs’ regulators. ● Shipment sent by Common Carrier (UPS) with link to DoC on shipping

papers (no hardcopy) ● Shipment held in customs by regulators who questioned DoC (6 March) ● Shipment placed on Ship Hold until proof of compliance provided ● Notice: 15 days to provide proof of compliance for applicable directives

● Radio and Telecommunications Terminal Equipment (RTTE) ● Electromagnetic Compatibility (EMC) ● RoHS2

Regulatory Action

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● Quick Response closes issue in 5 days: ● Collected Technical Files for the three applicable directives (from DRL) ● Sent to customs’ regulators for their review ● Obtain their acceptance of documentation in 48 hours ● Shipment released from Ship Hold on 11 March and sent to customer

with minimal delay.

● LESSONS LEARNED ● Providing DoCs online deemed acceptable by regulators ● Quick access to back-up documentation allows for rapid

compiling of documentation (common location) ● Technical File format generated by ITB deemed acceptable by

Dutch regulators ● Warning regarding compliance method – if technical file states

FMD will be collected to prove compliance, then compliance will only be achieved if all parts have FMD.

Response

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Declaration of Conformity

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Technical File

16 ©2014 Schneider Electric. All Rights Reserved. All trademarks are owned by Schneider Electric Industries SAS or its affiliated companies or their respective owners.

Make the most of your energy SM

TURA Continuing Education Conference – Global Toxics Policy Update (Session E)AgendaSchneider Electric Business OverviewSE-IT (APC) Business OverviewSlide Number 5Slide Number 6Blue Guide on the implementation of EU product rules 2014RoHS2 – Essential vs. CE Marking RequirementsChanges to product markingDocumentationSlide Number 11Slide Number 12Slide Number 13Declaration of ConformityTechnical FileMake the most of your energy SM