RoHS recast aka RoHS 2 and UV curing printing devices

By Erik Vlietinck, J.D. Publisher of IT Enquirer (http://it-enquirer.com)!

PART I: General introduction to EU legal decisionmaking

The aims set out in the EU treaties are achieved by several types of legal act. Some are binding, others are not. Some apply to all EU countries, others to just a few. !
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! 1! Published Jan 01, 2014!

Regulations
A Regulation" is a binding legislative act. It must be applied in its entirety across the EU. For example, when the EU wanted to protect the names of agricultural products coming from certain areas such as Parma ham, the Council adopted a regulation. !

Directives
A "Directive" is a legislative act that sets out a goal that all EU countries must achieve. However, it is up to the individual countries to decide how. This was the case with the working time Directive, which stipulates that too much overtime work is illegal. The Directive sets out minimum rest periods and a maximum number of working hours, but it is up to each country to devise its own laws on how to implement this. !

Decisions
A Decision" is binding on those to whom it is addressed (e.g. an EU country or an individual company) and is directly applicable. For example, when the Commission issued a decision ning software giant Microsoft for abusing its dominant market position, the decision applied to Microsoft only. !

Recommendations
A Recommendation" is not binding. When the Commission issued a recommendation that pay structures for nancial-sector employees should not encourage excessive risk taking, this did not have any legal consequences. A recommendation allows the institutions to make their views known and to suggest a line of action without imposing any legal obligation on those to whom it is addressed. !

Opinions
An Opinion" is an instrument that allows the institutions to make a statement in a non-binding fashion, in other words without imposing any legal obligation on those to whom it is addressed. An opinion is not binding. It can be issued by the main EU institutions (Commission, Council, Parliament), the Committee of the Regions and the European Economic and Social Committee. While laws are being made, the committees give opinions from their specic regional or economic and social viewpoint. For example, the Committee of the Regions issued an opinion on how regions contribute to the EU's energy goals. !

The ordinary legislative process

The ordinary legislative procedure gives the same weight to the European Parliament and the Council of the European Union on a wide range of areas (for example, economic governance, immigration, energy, transport, the environment and consumer protection). The vast majority of European laws are adopted jointly by the European Parliament and the Council. ! The "co-decision" procedure was introduced by the Maastricht Treaty (1992), and extended and made more effective by the Amsterdam Treaty (1999). With the Lisbon Treaty that took effect on 1 December 2009, the co-decision procedure was renamed to "ordinary legislative procedure". It became the main legislative procedure of the EU's decision-making system. !

Decision process
The EU's standard decision-making procedure implies that the directly elected European Parliament has to approve EU legislation together with the Council (the governments of the 27 EUcountries). The Commission holds the right to take the legislative initiative. !

Drafting EU law
Before the European Commission proposes new initiatives it assesses the potential economic, social and environmental consequences that they may have. ! Impact assessment is a documented set of logical steps which helps the Commission to do this. It is a process that prepares evidence for political decision-makers on the advantages and disadvantages of possible policy options by assessing their potential impact. ! The Commission believes that the most effective way of improving the quality of new policy proposals is by making those people who are responsible for policy development also responsible for assessing the impact of what they propose. To this end, the Commission has rolled out a wide-ranging impact assessment system based on an integrated approach which analyses both benets and costs, and addresses all signicant economic, social and environmental impacts of possible new initiatives. ! This approach ensures that all relevant expertise within the Commission is used, together with inputs from stakeholders. In doing so, it also enhances the coherence of initiatives across policy areas. The Commission's system is both accountable and transparent. It strives for full involvement of stakeholders. ! All impact assessments and all opinions of the Impact Assessment Board on their quality are published online once the Commission has adopted the relevant proposal. ! Impact assessment also helps to explain why an action is necessary at the EU level and why the proposed response is an appropriate choice. It may of course also demonstrate why no action at the EU level should be taken. !

The Commission also consults interested parties such as nongovernmental organisations, local authorities and representatives of industry and civil society. Groups of experts give advice on technical issues. Citizens, businesses and organisations can participate in the consultation procedure online. National parliaments can formally express their reservations if they feel that it would be better to deal with an issue at national rather than EU level. !

Review and adoption

The European Parliament and the Council review proposals by the Commission and propose amendments. If Council and Parliament cannot agree upon amendments, a second reading takes place. In the second reading, Parliament and Council can again propose amendments. Parliament has the power to block proposed legislation if it cannot agree with the Council. ! If the two institutions agree on amendments, the proposed legislation can be adopted. If they cannot agree, a conciliation committee tries to nd a solution. Both the Council and Parliament can block the legislative proposal at this nal reading. ! Conciliation is the third and nal phase of the ordinary legislative procedure of the European Union. The conciliation procedure always applies if Council does not approve all the amendments of the European Parliament adopted at its second reading. The Conciliation Committee is made up of 27 Members of the Council or their representatives and an equal number of representatives from Parliament who make up the EP delegation. ! Inside the European Parliament the 27 members of the EP delegation in the conciliation Committee are appointed for each indi-

vidual conciliation procedure by the political groups. The composition of the delegations reects the overall political balance of Parliament. ! Three Vice-Presidents (currently Gianni Pittella, Rodi KratsaTsagaropoulou and Alejo Vidal-Quadras), are appointed as permanent members of the delegation. The chair of the competent committee and the rapporteur are also appointed ex ofcio. The Conciliation Committee has to be convened within six weeks (which may be extended by two weeks on the initiative of either institution) after the Council's second reading. The Committee has six (or eight) weeks to draw up a 'joint text' from the date of its rst meeting. ! Again within a period of six (or eight) weeks, the joint text is submitted by the Presidents of the EP and Council delegations for approval by the Parliament and the Council, without any possibility of amendment. If, on the other hand, the Conciliation Committee does not reach an agreement or if the 'joint text' is not approved by Parliament or Council, the act is deemed not to have been adopted. !

Consultation
Consultation is a special legislative procedure, whereby Parliament is asked for its opinion on proposed legislation before the Council adopts it. The European Parliament may approve or reject a legislative proposal, or propose amendments to it. The Council is not legally obliged to take Parliament's opinion into account but in line with Court of Justice case-law, it must not take a decision without having received it. !

Consultation has become a special legislative procedure used in a limited number of cases. This procedure now applies to a limited number of legislative areas only, such as internal market exemptions and competition law. Parliament's consultation is also required, as a non-legislative procedure, where international agreements are being adopted under the Common Foreign and Security Policy (CFSP). ! In certain legislative areas, the European Parliament is requested to give its consent, as a special legislative procedure under Article 289(2) of the Treaty on the Functioning of the European Union (TFEU). The consent procedure gives Parliament the right of veto. Parliament's role is thus to approve or reject the legislative proposal without further amendments and Council cannot overrule Parliament's opinion. Consent is also required as a non-legislative procedure when Council is adopting certain international agreements. ! Formerly know as the assent procedure, this was introduced by the 1986 Single European Act in two areas: association agreements and agreements governing accession to the European Union. The scope for the application of the procedure was extended by all subsequent modications of the Treaties. ! Alongside the main legislative procedures, there are others that involve Parliament in specic areas. !

Provisions on implementing and delegated provisions

The Commission may introduce implementing provisions for existing legislation. These provisions are presented to committees of

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experts from the Member States and forwarded to Parliament either for information or scrutiny. On a proposal from its committee responsible, Parliament may adopt a resolution opposing the measure, stating that the draft implementing measure exceeds the powers laid down in the legal act concerned, is not compatible with the aim or the content of the basic instrument or does not respect the principles of subsidiarity or proportionality, and ask the Commission to withdraw or amend the draft of measures or submit a proposal under the appropriate legislative procedure. ! Where a legislative act delegates to the Commission the power to supplement or amend certain non-essential elements of a legislative act, the responsible committee examines any draft delegated act where it is transmitted to Parliament for scrutiny and may submit to Parliament in a motion for a resolution any appropriate proposal in accordance with the provisions of the legislative act. !

The legislative initiative as extended under the Maastricht Treaty

As we've seen earlier, the Commission has the ordinary legislative initiative. However, under the Treaty of Maastricht enhanced by the Lisbon Treaty, the European Parliament has a right of legislative initiative that allows it to ask the Commission to submit a proposal. ! On the basis of a report by one of its committees, Parliament, acting by a majority of its Members, may request the Commission to submit any appropriate legislative proposal. Parliament may

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simultaneously set a deadline for the submission of such a proposal. A proposal may also be initiated by an individual Member of the European Parliament. Such a proposal shall be submitted to the President of the Parliament who refers it to the committee responsible for consideration. It may decide to submit it to the plenary. !

Own-initiative reports
In the areas where the treaties give the European Parliament the right of initiative, its committees may draw up a report on a subject within its remit and present a motion for a resolution to Parliament. They must request authorisation from the Conference of Presidents before drawing up a report. !

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PART II: ROHS 2 and mercury (as found in classical UV curing lamps)
RoHS (Restriction of the use of certain hazardous substances in electric and electronic equipment 1) recast (RoHS 2), WEEE (Waste Electrical and Electronic Equipment 2) recast (WEEE 2) and REACH (Registration, Evaluation, Authorisation and Re-

! 1! Dir. nr. 2011/65, 8 June 2011 on the Restriction of the use of certain hazardous substances in electrical and electronic equipment (recast), O.J..L174, 1.7.2011. p. 88.! ! 2! Dir. nr. 2012/19, 4 July 2012 on waste electrical and electronic equipment (WEEE) (recast), O.J., L 197, 24.7.2012, p. 38.!

striction of Chemicals 3) are three legislative instruments that allow the EU to reach its long-term objectives in the area of environment and consumer protection. ! Both RoHS 2 and WEEE 2 are Directives. REACH is a Regulation. In terms of importance for UV curing lamps, RoHS 2 and REACH are the most important legal instruments. They both have direct consequences for the use and phasing out of mercury and its derivatives. WEEE has its merits for understanding the implications of RoHS 2 and REACH on the use of chemicals in equipment and products both on a consumer and industrial level. ! RoHS 2 seeks to decrease the use of toxic materials and consumables in products used by end-users and "professionals" (sic RoHS 2 & WEEE Directive). REACH is meant to protect professional users as well as the environment by enforcing strict rules

! 3! Reg. nr. 1907/2006, 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals Agency, amending Directive 1999/45/EC and repealing Council Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC, O.J. L 396, 30.12.2006, p. 1. ! ! 3! Reg. nr. 1907/2006, 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals Agency, amending Directive 1999/45/EC and repealing Council Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC, O.J. L 396, 30.12.2006, p. 1. !

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of usage, stockage and waste disposal of dangerous and/or toxic chemicals. REACH therefore mainly targets industrial users. ! To further complicate matters, RoHS 2, WEEE and REACH all have impact on end-users as well as "professionals" in specic areas. ! Being Directives, both RoHS 2 and WEEE contain the general rules the Member Countries must implement by way of statutes and legal instruments as well as practical measures to enable them. This implies that, for example, the mercury in end-of-life uorescent ofce lights will need to be disposed of without impacting the environment, but the methods and technology used, and the way costs are amortised, are freely decided upon by the Member Countries. This is not the case with REACH.! Note that some member countries may be too late with implementing a Directive. Such failures will expose them to legal procedures initiated by the Commission before the Court of Justice of the EU. So far, this hasn't happened with RoHS or WEEE. ! Also note that RoHS 2 entered into force on the 21 of July 2012, but required member states to transpose the provisions into their respective national laws by the 2nd of January 2013. On that date, the Commission revoked RoHS 1. !

Exemptions and review planning

Both RoHS 2 and WEEE have a list of exemptions. These are restricted in scope and duration, and apply only to components and substances for which no alternatives (are believed to) exist. In the

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RoHS 2 Directive we nd the exact criteria for exemption in Recital (18): ! Whereas: ... (18) Exemptions from the substitution requirement should be permitted if substitution is not possible from the scientic and technical point of view, taking specic account of the situation of SMEs or if the negative environmental, health and consumer safety impacts caused by substitution are likely to outweigh the environmental health and consumer safety benets of the substitution or the reliability of substitutes is not ensured. ! RoHS 2s scope shall be amended before 22 July 2014, as stated in Art. 6,1 by the Commission:! ...and periodically thereafter on its own initiative or following the submission of a proposal by a Member State containing the information referred to in paragraph 2. ! The review and amendment of the list of restricted substances in Annex II shall be coherent with other legislation related to chemicals, in particular Regulation (EC) No 1907/2006 (ed. : REACH), and shall take into account, inter alia, Annexes XV and XVII to that Regulation. The review shall use publicly available knowledge obtained from the application of such legislation. ! In order to review and amend Annex II, the Commission shall take special account of whether a substance, including substances of very small size or with a very small internal or sufce structure, or a group of similar substances: ! ! 1.!could have a negative impact during EEE waste management operations, including on the possibilities for prepar-

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ing for the reuse of waste EEE or for recycling of materials from waste EEE; ! ! 2.!could give rise, given its uses, to uncontrolled or diffuse release into the environment of the substance, or could give rise to hazardous residues, or transformation or degradation products through the preparation for reuse, recycling or other treatment of materials from waste EEE under current operational conditions;! ! 3.!could lead to unacceptable exposure of workers involved in the waste EEE collection or treatment processes; ! ! 4.!could be replaced by substitutes or alternative technologies which have less negative impacts. ! Also by July 2014, the Commission shall review the list of restricted substances. Others will follow periodically after the rst one but no further dates are mentioned. During the rst review at the least, a thorough analysis of the Directives coherence with REACH must be carried out by the Commission ! (Recital 28). To secure coherence between RoHS 2 and REACH both the methodology for prospective substance restrictions and criteria for granting exemptions should be coherent with REACH. ! The available information according to the REACH procedures shall be used for future substance-related RoHS 2 amendments. Furthermore, when overlaps between RoHS 2 and REACH occur, the strongest restriction will apply. Finally, exemptions from the substance restrictions in RoHS 2 may not be granted if they

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result in a weakening of the environmental and human health protection afforded by REACH.!

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PART III: Phase-out timing of mercury in RoHS 2

Mercury is a toxic element that RoHS 2 aims at phasing out from all equipment with only a few except ions. These exceptions are listed under multiple Articles, Annexes and Recitals. Furthermore, in order for toxic elements to be included in the ban of RoHS 2, they need to be in scope. The system is further explained hereafter.! Article 4.1 of the RoHS 2 Directive reads as follows:! Applications exempted from the restriction in Article 4.1: Member States shall ensure that EEE placed on the market, including cables and spare parts for its repair, its reuse, updating of its functionalities or upgrading of its capacity, does not contain the substances listed in Annex II.! Annex II lists mercury as one of the substances which are not tolerated unless the maximum concentration remains under 0.1%

of the weight in homogenous materials. Annex III of RoHS 2 lists all exceptions to this rule for mercury.! For UV curing lamps, the last item in the list (4(f)) is the one to focus on. This is the category to which UV curing lamps belong. Next to this category, there is no mention of an expiration date for the exemption. ! In RoHS 2, exemptions expire automatically on July 22, 2016 if no prior dates are listed in the Annex and/or the Commission will not foresee in an earlier date when the rst review round has nished. However, this category needs to be read in concordance with Article 2.4, which lists the criteria to determine whether a product or installation is out of scope.! Article 2.4 reads as follows:! 4. This Directive does not apply to: (...) ! ! !(d) large-scale stationary industrial tools;! ! !(e) large-scale xed installations;! (...).! For the mercury category in Annex 4(f) this means we should rst and foremost determine whether the lamp is installed as part of a large-scale stationary industrial tool (LSSIT) or a large-scale xed installations (LSFI). Hence, to determine whether UV curing mercury vapour lamps are exempted or not, we rst need to dene what makes a LSSIT and/or a LSFI in the context of RoHS 2.! The Commission has listed guidelines for this important denition. If the lamp is not installed in a LSSIT/LSFI, its exemption date is July 22, 2016, unless the Commission amends to an earlier timing. Amendments even revoking exemptions are possible at all times and especially during the review period.!

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What makes a LSSIT and/or a LSFI in the context of RoHS 2.

The Commission has listed guidelines for this important denition. If the lamp is not installed in a LSSIT/ LSFI, its exemption date is July 22, 2016, unless the Commission amends to an earlier timing. Amendments even revoking exemptions are possible at all times and especially during the review period. ! What is a LSSIT and/or a LSFI in the context of RoHS 2? Both terms are dened by Articles 3,3 and 3,4. However, it is not explained what is meant by "large-scale". Both categories are combinations of various types of items, such as machinery, components etc. for permanent use at a specic place, installed and de-installed by professionals. Therefore the two categories may overlap. However, it is important to consider that the meaning of "large-scale" in absolute terms may be a different one for tools and installations, as there are differences between tools and installations. ! Tools are essentially machines, stand-alone or assemblies, often with moving parts, and used for example for the treatment or manufacturing of materials and work pieces. The Machinery Directive can be used here as a guidance. Typical machine tools can also be part of xed installations. ! In order to benet from either exclusion i.e. be considered out of scope in RoHS 2 the tool or installation must meet all the respective requirements. ! It has to be: !

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! 1.!A Tool, which is:! ! ! ! ! !an assembly of machines, equipment and/or components, functioning together for a specic application; ! !permanently installed and de-installed by professionals at a given place; ! !used and maintained by professionals in an industrial manufacturing facility or R&D facility;! !large-scale.!

! 2.!An Installation, which is:! ! ! ! ! !a combination of several types of apparatus and, where applicable, other devices; ! !assembled, installed and de-installed by professionals; ! !with the intention to be used permanently in a predened and dedicated location; ! !large-scale. !

"Large-scale" is part of both sets of requirements. This draws a line between "larger" tools and installations beneting from an exclusion, and otherwise similar, "smaller" equipment. "Large-scale" refers to dimensional or similar criteria as explained below, although this criterion is not specied in the RoHS 2. ! It is the responsibility of the manufacturer, importer, or any other economic operator involved to assess whether his tool or installation benets from either exclusion.! Due to the nature of both denitions, assigning broad types or classes of equipment to either category is not possible. Decisions are to be taken on a case-by-case basis considering all criteria in

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each denition. The following non-exhaustive lists of examples and criteria has been developed by the Commission to support those decisions. ! Examples of large-scale xed installations (beneting from an exclusion): ! ! !Production and processing lines, including robots and machine tools (industrial, food, print media etc.); ! ! !Passenger lifts; ! ! !Conveyor transport systems; ! ! !Automated storage systems; ! ! !Electrical distribution systems such as generators; ! ! !Railway signalling infrastructure; ! ! !Fixed installed cooling, air conditioning and refrigerating systems or heating systems designed exclusively for non.residential use. ! ! !Machines for the industrial production and processing of materials and goods, such as:! ! ! ! ! !CNC lathes; ! !Bridge-type milling and drilling machines;! !Metal forming presses; ! !Newspaper printing presses; !

! !Machines for the testing of work pieces, such as:!

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! ! ! !

!Electron beam, laser, bright light, and deep ultra violet defect detection systems; ! !Automated integrated circuit board and printed wiring board testers; ! !Cranes; ! !Other machinery of similar size, complexity and weight. !

Examples of large-scale stationary industrial tools (beneting from an exclusion): ! The Commission states that tools and installations that do not fall within the examples above should be assessed individually with respect to the wording of the exclusions. The burden of proof is with the responsible economic operator. Where a tool or installation does benet from the exclusion, all its constituent components that are part of it when placed on the market are also excluded. ! Machinery that has partial mobility, for example semi-mobile machinery running on rails, can be of 'permanent use'. On the other hand, EEE that is intended to be used on different sites during its life is not considered as permanent. It is an indicator of permanent use if the equipment is not readily re-locatable (or 'mobile intended') and if it is intended for use at one single location. ! As for the industrial context for professional installation and de-installation, scenarios such as the need for special assembling equipment, required permits, if the commissioning is a professional engineering exercise, specialised training, considerable installation time etc. can be indicators. !

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As regards "large-scale", this is especially relevant to tools such as stand-alone industrial machines placed individually on the market, "Large-scale" can be used to identify and differentiate between tools because of their size, weight, capacity, throughput or other performance related criteria. It also relates to tool or installation complexity, and to the effort needed for installing, operating, maintaining and de- installing a tool or an installation. ! One possible way of introducing a direct size criterion relates to transportation. The following guidance metrics and qualitative criteria are given by the Commission to be applied for installations. If the installation exceeds the minimum requirements for one of the following criteria, it can be considered large-scale: ! ! !If, when installing or de-installing the installation, it is too large to be moved in an ISO 20 foot container because the total sum of its parts as transported is larger than 5,71 m x 2.35m x 2,39m, it can be considered large-scale. ! ! !The maximum weight of many road trucks is 44 tonnes. Thus if, when installing or de-installing the installation, it is too heavy to be moved by a 44 tonne road truck, because the total sum of its parts as transported weighs more than the truck's load capacity, it can be considered large-scale. ! ! !If heavy-duty cranes are needed for installation or de-installation, the installation can be considered large-scale. ! ! !An installation that does not t within a normal industrial environment, without the environment needing structural modication, can be considered large-scale. Examples for modications are modied access areas, strengthened foundations etc. !

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! !If an installation has a rated power greater than 375 kW, it can be considered large-scale. ! This is only an indicative list, but from the above we can already conclude that most UV curing printing devices are not out of scope and therefore their mercury UV curing lamps will need to be replaced by other UV curing technology by mid-2016.! Tools that are large-scale in comparison to smaller industrial tools can be signicantly smaller than large-scale installations. Therefore, tools do not need to match the above listed criteria for installations. However if they do, they are in any case large-scale. The following criteria can be applied to tools as installed, but specic guidance metrics should be developed. Any of the following criteria can be an indicator: ! ! !Dimensions; ! ! !Tool size; ! ! !Size, movement or force of moving parts; ! ! !Weight. ! Where the size or weight of a tool or an installation is close to the guidance metrics for large-scale, or where it is difcult to determine its exact size or weight with regard to its classication as large-scale, complexity or required utilities may be taken into consideration as a qualitative indicator. An indicator of complexity is that the tool consists of several hundred components interrelated to form subsystems for process parameters which comprise the tool's intended function. Indicative utilities may include special power connections and utility connections other dian clean dry air or water supply and drain, such as high pressure com-

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pressed gas supply, vacuum lines, toxic or heat exhaust connections, or chemical supply lines and drains. ! In order to ensure legal certainty, the Commission states that specic guidance metrics for large-scale tools based on available technical data should be developed in the course of the implementation and enforcement of RoHS 2, and incorporated in a revised version of this guidance document. The benchmarks for large tools should be between and signicantly different from those for large household appliances as discussed under WEEE 2, and those for large installations as listed in this document. !

Responsibility for items that are to be used in LSSIT/LSFI

RoHS 2 does not apply to equipment which is specically designed and is to be installed as part of a LSSIT or a LSFI. The obligations of RoHS 2 will therefore not apply as such to the manufacturer of EEE and the different parties in the distribution chain. ! However, any given manufacturer may nevertheless have to ensure and establish that his equipment is part of another type of equipment that falLs outside the scope of RoHS 2, that can only function as part of this equipment and can be replaced only by the same specically designed equipment. ! The other parties may then have to provide documentation and information to this extent. Despite the absence of installers' obligations in the text of the RoHS Directive, one cannot exclude that the installer who does not manufacture the equipment at issue

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would have to bear such documentation and information responsibilities. !

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PART IV: Industrys perception of RoHS 2

I asked feedback from multiple trade associations familiar with UV curing in Europe. The few who wanted to participate gave evidence of a blatant ignorance with regards to the exact meaning of the Directives, their scope and the impact they may have on their members operations.! One of the printing trade associations answered that UV mercury lamps will not disappear quickly because many applications cant use LED UV lamps. Screen printers told the association they need these lamps:! The feedback from the members is that the market and products are re-positioning but not under pressure of this legislation but rather on technological improvements.!

A European association of UV curing equipment manufacturers believes the interpretation of LSSIT/LSFI is straightforward and all UV curing installations are LSSITs, which isnt necessarily so and which can only be determined on a case-by-case basis per the legal instruments wordings itself. For example, a UV curing printer that ts in a photo studio can hardly be categorised as a LSSIT/LSFI.! One worldwide manufacturer of UV curing inkjet printers believes their manufacturing and OEM operations are affected only by REACH, not by RoHS 2 at all.!

What may postpone the mercury ban for UV curing printers?

To apply pressure or get something done on a legal level in the EU and specically with regards to the mercury ban there are four possible paths:! Right of petition ! Lobbying with members of Parliament to inuence Annex II (allowed percentage of substances in products)! Consultation (Article 6 adaptation of Annex I and/or II)! Using RoHS Annex V.! The rst two depend on political factors. The last methods are more objective and depend on scientic and fact-based information. Note that while they can contribute considerably to it, none of these methods guarantee the mercury ban being less fully and/ or slower implemented in the UV curing market. The ultimate

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target is to get rid of mercury as it is an environmentally disastrous and an incredible health hazard especially mercury vapour as the toxic in this form is absorbed by the blood and brain almost instantaneously.! The removal of materials and components of EEE from the lists in Annexes III and IV will only be deemed acceptable under specic conditions. If the elimination through design change or materials and components is scientically or technically impracticable, the EU will keep the exemption until its pre-dened expiration date. If the reliability of the substitute is not ensured, the exemption remains. If the total negative environmental, health and consumer safety impacts caused by a substitution are likely to outweigh the total environmental, health and consumer safety benets thereof, the exemption will be kept.

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