Mercury Use In Europe
The EU Parliament created two Directives that are designed to reduce the hazardous substances that may enter the waste stream in Europe. These Directives primarily target consumer products.
The two Directives are the WEEE (Waste Electrical and Electronic Equipment) Directive (2002/96/EC) and the RoHS (Restriction of Hazardous Substances) Directive (2002/95/EC) which took effect July 2006. The Directives are not retroactive and do not apply to products purchased before July 2006, nor do they apply to replacement parts for existing equipment in use before July 2006 (RoHS Aritcle 2, Par 3).
One of the substances being controlled by these Directives is mercury. Mercotac connectors contain a small amount of liquid mercury. However, because Mercotac products are used almost exclusively in industrial type machines, they are often exempted in those applications from control by these Directives. See the explanation following.
In the original RoHS directive, “large-scale stationary industrial” equipment, “medical devices” and “monitoring and control instruments” were exempted categories (RoHS Article 2, Par 1)(WEEE Annex 1A/1B, Categories 6, 8 and 9).
The EU Parliament and Council “recast” the RoHS and WEEE directives in 2011 (Directive 2011/65/EU), effective 21 July 2011. The scope of electrical products covered by the directives was expanded to include almost all electrical and electronic products. However, the current exceptions for “large-scale stationary industrial tools”, “medical devices”, and “monitoring and control instruments” are still valid (Article 2, Par 4(d) & Article 4, Par 3).
In addition, the Recast now includes additional exceptions for:
- “large-scale fixed installations” (Article 2, Par 4(e))
- “non-road mobile machinery made available exclusively for professional use”(Article 2, Par 4(g))
- “equipment designed solely for the purposes of research and development only made available on a business-to-business basis” (Article 2, Par 4(j))
The Recast RoHS will phase out the exempted categories 8 and 9 so that there will be no exceptions for “medical devices” or “monitoring and control instruments” placed on the market after 22 July 2014 (Article 4, Par 4(b & d)), or “industrial monitoring and control instruments” placed on the market after 22 July 2017 (Article 4, Par 4(e)). Replacements are allowed for products put into service before these dates.
Use the link below to view the Recast RoHS Directive:
*** Recast of RoHS Directive (effective 21 July 2011)
CE Mark for Europe
The WEEE and RoHS Directives now also require affixing a “CE” mark to products and machinery to indicate that “the product is in conformity with the applicable requirements set out in Union harmonisation legislation” (2011/65/EU, Article 3 (15)). However, Mercotac products are considered “passive components” to be incorporated into other electrical equipment and for which there are no specific electrical safety standards. Therefore, according to the EU Low Voltage Directive (2006/95/EC), Mercotac connectors can only be CE marked by the machine manufacturer based upon that particular application and electrical specifications. See the Guidelines On The Application of Directive 2006/95/EC”, page 7, section 9 & footnote 13.
REACH In Europe
On 1 June 2007, European Union Regulation (EC) No. 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (“REACH” for short) came into force. REACH specifies under Article 33 that manufactured “articles” require Safety Data Sheets only when the articles contain a Substance of Very High Concern (SVHC) or are intended to release a hazardous substance under normal use or disposal. The candidate list of 15 SVHC published on 28 October 2008 may be viewed at http://echa.europa.eu/chem_data/candidate_list_en.asp.
Mercotac® rotating electrical connectors are manufactured articles, not chemicals, and are not intended to release any substance under normal or reasonably foreseeable conditions of use or proper disposal. According to our current knowledge, no SVHC substances from the candidate list are present in our products. Therefore, no Safety Data Sheets are required for Mercotac® products under the REACH regulations.