“All these various pieces of legislation,” he said, “are trying to tackle the same thing – how to protect the environment."
Legislation such as RoHS – the Restriction of Hazardous Substances Directive – are intended to tackle the problem from the design perspective. “You have to know what’s in your products so they don’t cause problems later on,” said Poate. “Generally, for more mainstream products, companies have got a pretty good grip of the requirements, but the biggest impact is coming from REACH – the Registration, Evaluation, Authorisation and restriction of Chemicals Directive.”
Poate noted: “If I’m selling paint, then REACH obviously applies. But a manufacturer of office furniture will find REACH just as relevant, but in a different away; the desk may be painted, for example, or it might have a lacquer finish.
“It’s important that you manage your supply chain effectively,” he advised. “If someone challenges you, then you’ll be able to tell them exactly what’s in your product.”
But how do you tell people – and what are the legal requirements when it comes to labelling?
“There isn’t one piece of legislation that says ‘this is what you have to do’,” Poate admitted. “Labelling requirements derive from a number of different pieces of legislation.
“Electrical products will be tested to something like IEC6950, for example, and these standards will have a set of labelling requirements – but they are likely to be safety specific. For example, there’s the square in a square symbol for double insulation and the crossed out wheelie bin.
“Radio equipment is another example; the particular labelling requirements depend on what type of transmitter is being used and which market the device is being sold into.”
What if you’re required to provide a range of information, but your product is too small? “It’s easy to put a big label on a big piece of machinery,” Poate said. “But with things like a mobile phone, the necessary information can often be displayed on the device’s screen. Other solutions include pull out tags.”
Because there are no specific labelling requirements, some product developers are becoming more selective about what they put on the label – the CE mark might be the only visible mark. “Five or 10 years ago,” he continued, “it was a case of ‘let’s show all the certifications’. Today, products often have only a small area and some of the companies we talk to don’t want labels on their products because of styling issues.”
Are there innovative solutions, such as the use of NFC or RFID? “As soon as you say that you’ll need an RFID reader, you’ll be in trouble because people should be able to access information readily,” he warned. “A while ago, companies started thinking about supplying information on a CD – and that caused huge discussions. I think any move to more elaborate solutions will be some way off.”
Poate said TÜV is often asked ‘what do you think?’ when it comes to labelling. “If they want to do something novel, the only definitive decision will come from a court of law, so our advice is to follow best practice,” he concluded.
