WEEE Open Scope: 1cc’s Webinar on May 17, 2018

Businesses selling EEE across Europe will face considerable change in the near future regarding the requirements under the WEEE Directive 2012/19/EU. Starting August 15, 2018, all EEE in scope of the Directive have to be classified according to the new categorization. Furthermore, the ‘open scope’ will encompass further products under the EEE definition and thus become subject to WEEE obligations.

In order to help companies understand the changes throughout the transition period, 1cc will organize a webinar in May 2018.

Meike Ruoff, Director at 1cc GmbH, will provide an insight into the main updates and consequences of the WEEE Open Scope. The webinar will include examples of implementation in selected countries in the EU.

Title: WEEE Open Scope in EU: Consequences and Updates

Date: May 17, 2018, 3:00PM-4:00PM CEST

Language: English

Registration Link: https://attendee.gotowebinar.com/register/5157177215963441921

PS: Participation in the webinar is free of charge. However, the number of participants in the webinar is limited to 20 attendees.

Spain: New Categories already Applicable for Q1 2018 WEEE Reporting

The latest changes to the Royal Decree 110/2015 in Spain will enter into force on August 15, 2018.

However, new categories and sub-categories will be applicable for reporting as early as April 2018. Consequently, producers are required to submit the 1st quarter data report for the 7 new categories, as well (currently there are 10 categories).

The so-called ‘open scope’ is an important innovation in that the legal scope encompasses all electrical and electronic equipment.

Moreover, as of August 2018 new devices will be added to the scope:

-sensors, electric switches, electrical motors and generators

-print consumables, such as cartridges and toners that contain electronic or electric parts

-luminaires

All these devices will have to be declared, without exceptions.

We highly recommend that you pay close attention to the new criteria relative to the external product dimensions, where a distinction is made between small and large equipment with an edge length of more or less than 50 cm (see the attachment from EWRN)

The following points are especially important:

1. Are there any additional products that you have not yet registered?
2. Is an additional registration necessary? (based on the new product-dimensions criteria)

We would be pleased to place our expertise at your convenience and support you with the next necessary steps (i.e. additional registration, notification of request/correction of category).

For more information, please do not hesitate to contact us at info@1cc-consulting.com.

REACH: Registration Deadline on May 31, 2018: Important Hints and Considerations

In light of the upcoming registration deadline on May 31, 2018, companies that fail to register their substances under REACH are left with few options. In accordance with the principle “no data, no market” (Art. 5 REACH Regulation), it is recommended to register substances on time, when possible. Pre-registrations with compliant dossiers will become invalid and SIEFs inactive after the submission deadline (May 31^st). Registrations submitted after June 1^st will undergo more complex inquiry procedures.

It is important to note that selling stocks of unregistered substances produced in, or imported into the EU/EEA before the deadline can be risky, because downstream users may not be willing to use them.

However, ECHA provides assistance to registrants facing exceptional situations defined as follows:

• Lack of necessary data (on substances in mixtures, unavailability of data required in annexes VII and VIII),
• legal entity changes,
• failure of the lead registrant to complete his obligations before the deadline,
• SIEF without an EU manufacturer

For more information, please do not hesitate to contact info@1cc-consulting.com.

Vera Lebedeva: A New Team Member

Vera Lebedeva joined 1cc in January 2018 as a Consultant/Compliance Specialist with focus on REACH, RoHS and Conflict Minerals. Vera completed her Bachelor’s degree in International Relations and Political Science at the Moscow State Institute of International Relations (MGIMO University), where she additionally learned German. In the course of studies, Vera Lebedeva spent an exchange semester in Tuebingen/Germany. After attaining her degree in Moscow, Vera decided to resume her academic career in Tuebingen, where she graduated with a Master’s degree in Political Science.

Germany Introduced Revised Copyright Law

On March 1, 2018, the new German Law on the alignment of copyright with the current requirements of the Knowledge Society (Gesetz zur Angleichung des Urheberrechts an die aktuellen Erfordernisse der Wissensgesellschaft, UrhWissG) came into force. After careful scrutiny, it became clear that the legal provisions are relevant to the compliance efforts of IT/CE manufacturers: In short, the law broadens the scope of rights to private copying, which is remunerated via copyright levies.

The UrhWissG specifies the acts of copyright use in the field of education and science that are permitted without requiring the consent of authors and other right holders. This leads to the assumption that copyright fees may increase. However, there are no new or higher claims, or planned tariff adjustments other than the ones known by collecting societies.

Nonetheless, the notion of higher levy claims could be adopted in the current negotiations on products by collecting societies. Negotiations are underway in Germany on copyright levies for hard disks, among other things, and the claims might go up to 34 Euro per unit.

1cc will continue to monitor developments.

Conflict Minerals: New Regulatory Proposal in the U.S.

Many public companies in the U.S. are presently subject to disclosure requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act. The disclosure requirements relate to the use of conflict minerals originating in the Democratic Republic of the Congo or an adjoining country. The new regulatory motion calls for the repeal of those obligations:

According to Bill H.R. 4248, section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act is to be deleted entirely. The respective legal proposal was referred to the Committee for Financial Services in November 2017, which presented its report to the House of Representatives in February 2018. A final decision or legislation is pending.

ECHA Published New Candidate List

The European Chemical Agency (ECHA) has published an update of the Candidate List under REACH on January 15, 2018: Seven new substances of very high concern (SVHC) were added to the list. For Bisphenol-A, the already existing entry was updated.
The Candidate List of SVHCs for authorization now contains 181 substances.

Link to ECHA´s Website: https://echa.europa.eu/de/candidate-list-table

Eurasian Economic Union RoHS will come into force on March 1, 2018: Are you compliant with its requirements?

The Technical Regulation of Eurasian Economic Union (former Customs Union) TR EEU 037/2016 „On restriction of use of hazardous substances in electric and radio-electronic equipment“ will enter into force on March 1, 2018: Its substance restrictions apply to Lead, Mercury, Cadmium, Hexavalent Chromium, Polybrominated biphenyls (PBB) and Polybrominated diphenyl ethers (PBDE) with identical thresholds as in the EU. The product scope and the list of exceptions are very similar but not identical with EU RoHS requirements.

The most important differences, however, can be stated on the level of personal scope, of conformity assessment and of marking and labelling. Before a product can be placed on EEU market, it has to undergo a specific conformity assessment procedure including registration and receive a EEU conformity mark. This procedure can be initiated by producer, importer or their authorized representative subject to special requirements.

You need further assistance regarding compliance with EEU TR on RoHS? Please contact us at contact@1cc-consulting.com

ECHA Published New Candidate List

The European Chemical Agency (ECHA) has published an update of the Candidate List under REACH on January 15, 2018: Seven new substances of very high concern (SVHC) were added to the list. For Bisphenol-A, the already existing entry was updated.
The Candidate List of SVHCs for authorization now contains 181 substances.

Link to ECHA´s Website: https://echa.europa.eu/de/candidate-list-table

Merry Christmas and a Happy New Year

We wish our customers and partners a Merry Christmas and a Happy New Year!
Instead of gifts, we donate this year to the association Paulinchen e.V., which helps children with severe burns – www.paulinchen.de

Your 1cc Team