Consumer Electronic Manufacturers Compliance Questions: February 2018

February was a busy month for our Subject Matter Experts as lots of our consumer electronics clients had questions in relation to a wide range of subjects. You can find the full questions and answers below, but here is a summary of the topics covered:

  • REACH regulations in Russia
  • RoHS in Sweden
  • South African Electrotechnical Letter Of Authority (LOA) Administration Procedure
  • Hazardous waste in Serbia


1) Question: Can you clarify is there a new or specific regulation in Russia in relation to or similar to EU REACH requirements?

Answer: At present in Russia, there’s no single coherent REACH like regulation. In October 2016, a Government Decree No. 1019 approving a technical regulation for chemical product safety was enacted. This regulation applies to chemical products which include both substances and mixtures. It makes GHS (Globally Harmonized System of Classification and Labeling of Chemical) labels and safety data sheets compulsory for chemical products in Russia and sets out requirements on new substance notification and chemical product registration. This regulation will come into force on 1 July 2021.

In the meantime, chemical registration requirements under Law No 52-FZ of 1999 on “Sanitary and Epidemiological Well-being of the Population” and Government’s Decree no. 869 of 1992 concerning registration of potentially hazardous chemical and biological substances are still applicable. They require a mandatory state registration of potentially hazardous chemical and biological substances with the Federal State Establishment of Public Health (FSEH). Substances information to be provided cover a broad range of toxicological and ecotoxicological data, which are decided and evaluated on a case-by-case basis by the Federal Services.

Finally, since January 2017, there’s also a draft law on chemical safety (available for download in C2P, the compliance knowledge management platform) providing general measures to be taken by the Russian competent authorities to diminish possible chemical safety risks and align with international chemical safety related regulations (such as theGHS and the Stockholm POPs convention). The proposal encourages the Government to overhaul the currently very outdated and unclear legislation on chemicals and put in place coherent chemical registration rules and procedures as well as a comprehensive list of chemicals prohibited for use.


2) Question: Does the Swedish law go beyond the requirements of the EU RoHS (Restriction of Hazardous Substances) directive?

Answer: Sweden has not imposed stricter substance limits than EU RoHS, and is a direct implementation of the Directive.


3) Question: What are the points of differences between 2018 version of the South African Electrotechnical Letter Of Authority (LOA) Administration Procedure and the previous version?

Answer: I have compared the two versions and the only change that I could find is in Section 7 which relates to Payments and Costs. The 2018 version refers to a non-refundable fee of R1950.00 per application whilst the fee payable prior to that was R1840.00. The individual application fees for safety and for energy efficiency have increased from R1840.00 to R1950.00 Vat whilst the application fee for both safety and energy efficiency has also increased from R3680.00 to R3900.00.

No changes appear to have been made to the LOA validity period or the evaluation process.


4) Question: Is waste electrical and electronic equipment (WEEE) considered a hazardous waste in Serbia?

Answer: WEEE is regulated in Serbia through the “Management of Waste from and Hazardous Substances in Electrical and Electronic Equipment, Regulation, 2010”. Article 11 of this Regulation deals with the transfer of WEEE and states that a Hazardous Waste Movement Document is required for the transfer of Non-Household WEEE by the end user to a distributor, collector, operator or collective operator.

This is not a requirement for the transfer of household WEEE but does apply to non-household WEEE.

I attach an English translation of the text for you. This translation is also available on the source in C2P.

Products covered include: Audio Visual Equipment, Circuit Breakers, Electrical and Electronic Equipment, Electrical and Electronic Tools, Fluorescent lamps, Incandescent Light Bulb / Electric Light bulb, Information Technology Equipment, Large Household Appliances – Electrical, Lighting Equipment / Luminaires, Plugs, Small Household Appliances – Electrical, Sockets / Outlets, Switches, Transformers and Water Heaters.

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