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FAQ in OUTDO Fitness certifications

Large scale industrial tools are specifically exempt under category 6. There is no present clear guidance on the scope of jhc covered by this exemption and it is therefore difficult for us to give advice with certainty. Our present view is based on all of the following criteria:

Consist of a combination of equipment, systems, products and/or components (therefore not a singe discrete tool such as a small or medium scale lathe, milling machine or pillar drill) .
Be a tool and not be covered under any other category
Be required to be fixed to operate safely or within specification
Be of 'large-scale'
Require professional installation
Only be used in an industrial environment
Be built to perform a specific task
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These are not specifically mentioned in the draft regulations nor the directive. The DTI 's view is that Article 2, subpoint 3 of the WEEE Directive includes a derogation for 'Equipment which is connected with the protection of the essential interests of the security of Member States, arms, munitions and war material shall be excluded from this Directive. This does not, however, apply to products which are not intended for specifically military purposes.'

The point about products not intended for specifically military purposes means that for example a radio supplied to the military, but also used by civilians, would still have to comply with the requirements of RoHS.

No, just being fixed is not sufficient. The intention of the fixed installation exclusion follows the same principles as the exclusion for vehicle mounted equipment. 'Products that become part of a product that is outside the scope of the directive are outside the scope of the directive'. In the case of fixed installations the intention is that the product becomes part of the fabric of the building. Once fitted is the equipment discernable from the rest of the building or has it become part of the building? If a business were to move would they be likely to move or leave the product? Lifts, electric doors and gates etc are fixed installations, fitted kitchen appliances, large fixed equipment, cctv camera systems are not.

All parts sold as part of the product are capable of being considered part of the product for the purposes of RoHS. Whether a part is considered part of the product may depend upon such considerations as interdependence, expected inclusion in WEEE and product description. This may include items such as:

Playing pieces or dice in a game requiring electricity to play

Cases supplied with the product (example: a protective case supplied with a power tool)

It does not include items such as