Agenda - Regulators EEE Scope Panel 15 October 2019

1. Date for next meeting

2. Terms of Reference – Some changes suggested in May. Any further comments?

3. Previous Actions:

Chris Grove is collating scope queries answered since advent of Open Scope Nigel Harvey to forward Eucolight lamp definition as some producers struggle to differentiate between lamp and luminaire. – Completed:

4. Lamp v Luminaire

‘A lamp is a replaceable electrical device that produces light from electricity, that can also have other functions*. They are intended to be used in luminaires amongst other devices. These lamps usually have a base made of ceramic, metal, glass or plastic, which secures the lamp in a standardized socket, which may be made with a screw thread base, two metal pins, two metal caps or a bayonet cap (See CEI/IEC 60061-1 standard) to allow the replacement of the lamp without tools”

*for example: lamp which functions as a camera or motion sensor; lamp which functions as a perfume dispenser; lamp which functions as an insect repellent”

The word “usually” allows for the fact that there are many specialist lamps that do not have a base, and do need tools to replace them.

Full guidance: https://docs.wixstatic.com/ugd/808a33_a2cef5e474564bd282e3fd3f11aa2cdc.pdf

WSF EEE Scope Panel are aware of two slight differences from the Eucolight guidance to UK guidance; firstly, in the UK, LED strips are in scope (the difference in Eucolight guidance is due to there being differing opinions in different Member States). The second point is that in the UK LED modules are in scope. WSF EEE Scope Panel agree that for these points, there is no change to UK guidance.

5. Components v finished products - The Agencies intend to produce guidance here. Following the previous meeting we became aware of EWRN Guidance and would appreciate comments on this to feed into our forthcoming guidance.

6. Transportation exemption

7. Update of Gov.uk scope guidance

WSF EEE Scope Panel

8. Categorisation of equipment in other legislation, and the effect on WEEE categories o Recently a producer has mentioned that set top boxes have been included as IT equipment under Eco Design requirements, which is

different from the categorisation in the WEEE legislation (consumer equipment). We assume that the WEEE legislation categories are “stand alone” but confirmation of this would be extremely useful

9. Response times and processes o Timings for confirmation of WSF EEE Scope Panel questions and decisions o Agree a date and timeline for any agreed items to be included on the GOV.UK guidance o Copies of decisions provided by the Agencies in the interim

10. Items for discussion:

Pic Description and Link to Example In or Out of ScopeHousehold Fuses

In scope Out of Scope Sold to end user as finished product Considered spare part

Listed in scope by EWRN Guidance, ‘Fuses are ready to use for end-user; No further processing is necessary.’

Starters for fluorescent lights In scope Out of Scope Sold to end user as finished product Considered spare part

Analogous with fuses?

110V Transformer Cat 9? Cat 6? Dual Use?

110V Power Tools Reduced risk of fatal shock over 240V Designed for site use Mandatory on many sites

Cat 6 Dual Use?

3 Phase Tools 415V Require 3 phase supply not common in UK

domestic property

Dual Use?

Pre Lit Xmas Tree Mains powered LEDs are not replaceable

In Scope Cat 5 (guidance already lists decorative lighting

chains) Still in scope if battery powered Still in scope Cat 5 if LEDs are replaceable,

replacement LEDs would be Cat 13

Bike Helmet with lights Light(s) integral to helmet

In Scope Cat 7

Helmet Mounted Light Supplied as separate product to helmet Attaches to helmet via strap

In Scope Cat 2

Industrial Vacuum Cleaner Cat 2 or 6?

In Scope Cat 2 in line with Regs

Bird Scarer Ignites burst of gas which makes loud bang

to scare birds (e.g. on landfill sites/crops)

In Scope Cat 6

July WSF EEE Scope Panel Call ItemsAC Current or Voltage Transmitter or Isolator

In, cat 9

Ride on golf caddy Require further guidance from the Agencies regarding transport exclusion

Toys Limited, novelty electrical functionality, for example a limited number of sounds, would be out of scope. However if the functionality is fundamental to the toy, for example an educational toy which provided sound, would be in scope.

Chip and pin readers with boards games In, cat 7.

Question for the Agencies: Would the weight of the whole game be in scope, or just the electrical product?

Books with electrical toy / game included Out of scope, basic function

Trampoline with speakers – noise on each bounce

Out of scope, basic function

Play tent with lights Out of scope, basic function

Childs bed with fairy lights Out of scope, basic function

Childs bed with tablet Out of scope, basic function

Bedtime light projectors In, cat 5

Question for the Agencies: BS:EN60598 is the luminaire standard. Could this standard also be used to ascertain if a product falls in scope?

Multi function night light In, cat 5

Cuddly toy with light projector and sound Case-by-case basis, depending on the product main function

If in, cat 7

Light-up bouncy ball Case-by-case basis, depending on the product main function

Out of scope if only used for novelty function

In scope if fundamental functionality e.g. night time dog walking

Plush toys which make sounds and move when squeezed

Case-by-case basis, depending on the product main function

Question for the Agencies: The scoping advice appears to be inconsistent, however we understand that we

are not able to see the exact product which was queried. Our understanding would be that a plush toy with limited sound and movement would be out of scope (as the basic function of a toy would not require the additional electrical functionality) however if the movement and sound were more fundamental to the toy, it would be in scope. Would it be possible to confirm our understanding?

Playset with figurines. Playset has centre console with lights and sounds and smoke from a chimney

Out of scope

Cash register which lights up and makes cash register sounds

Case-by-case basis, depending on the how reliant the product is on sound and movement

Light up cake decorations Out, novelty function

Light up birthday badge Out, novelty function

Trainers with LED lights. This could either be trainers with “novelty” lights, or trainers with specific function e.g. being seen when running at night

Case-by-case basis, depending on the product main function Out of scope if only used for novelty function In scope if fundamental functionality e.g. being seen at night when running

Single loop temperature controller In, cat 9 Lighting distribution boxes In, cat 9 Underwater scooter In, cat 7 Bike helmet with integral light Case-by-case basis, depending on the product main

function, with particular reference to marketing. In scope if there is more than one electrical function e.g. light and Bluetooth If in scope, cat 7, if marketed as key to the product.

Gloves with integral lights e.g. used by mechanics

In, cat 2

LED lighting for boats and yachts Out of scope, if designed and installed in an out of scope piece of equipment. In scope if generic lighting sold separately. In scope if retro-fitted as long as not specific to the out of scope product

Heated toilet seat Out of scope Remote controlled demolition robot Require further guidance from the Agencies.

Likely to be out of scope due to military use or “off-road mobile machinery only for professional use”

Solar power e.g. storage units, power supply emergency units, water heating units or electrical car chargers?

In, cat 10 for energy storage unit In, cat 1 for water heating unit

Virtual Reality headsets In scope If sold with a product then would be included in category of the product. If can be used with multiple products, or stand alone, may be cat 7 or cat 4 depending on whether it records images

Electric vehicle charge points In scope. Cat 10 if only has charging function Cat 9 if has additional monitoring function

Prosthetic limbs Out of scope as this is specialist equipment, or may be implantable depending on the product.

Rebreather PPE Case-by-case basis, depending on the product main function. May be in or out of scope, for example would be out of scope if specific military use.

Handheld scoreboards / substitute boards In scope Question for the Agencies: would the category depend on the use? For example we would assume that if used for sport occasions, the board would fall in cat 7.

However if this is just used for lighting then would be in cat 5. If the lamps were replaceable, the lamps’ should be recorded in category 13 unless they are out of scope.

e-cigarette refill Out of scope if no active electrical feature and consumable

July WSF EEE Scope Panel Call Items Product description Initial / provisional scoping view: For

discussion with the WSF EEE scope panel / confirmation with the Agencies

View Following WSF EEE Scope Panel Call – to be confirmed by the Agencies

Near Field Communication device to be added to non-electrical product (similar to contactless payment)

Possibly out of scope as would not be the basic function of the product it is attached to, however may depend on the point of the supply chain

Out of scope, based on following the logic that chip and pin cards are out of scope. Confirmation from the Agencies requested please. Question for the Agencies Schemes have previously been advised that chip and pin cards used in a set top box would be in scope. SIM cards are also in scope. Would it be possible to confirm if the following products are in or out of scope: chip and PIN bank cards; chip and PIN cards for other functions e.g. set-top boxes; SIM cards; Near Field Communication devices

Car media stereo device - sold directly to end users which is fitted into a vehicle after the vehicle manufacture.

EA feedback already provided. Falls under the exemption of “a piece of equipment that’s designed for and installed in another type of equipment”. Out of scope on the basis that they are designed for use in a vehicle and would not function on its own without it.

Agreed

Hoists for cars - electrical hoists mounted into car boots to help load mobility scooters into cars. There are also hoists that help people get into cars. The hoists are fixed into cars but

EA feedback already provided. If this were designed to be permanently installed into a vehicle and was specifically designed to fit the car boot space and only

Agreed

some can also be taken off the car and put onto a mechanical base with wheels that can then allow movement away from the car.

function there (perhaps because it was wired into the car battery power supply), this could be considered out of scope. However, this item would be in scope on the basis that not only is it sold separately to the vehicle, but it can be removed and operated without being permanently fixed to the car. Suggestion is for it to be reported in category 6.

Automatic doors - made up of doors, framework and an electronic device that controls the movement of the doors.

EA feedback already provided. When these are sold as one unit with the control system, framework and doors all together, the entire package would be declared in scope and the whole weight reported. Automatic garage doors are also considered in scope and like this case, although some work is required to fit the doors into place, it is not on the same scale as the amount of infrastructure that is required with examples that do fit into the fixed installation criteria such as a lift. Where the electronic device that controls the movement of the doors is sold as a standalone product, the device would be in scope and in category 9.

Agree that these products are not fixed installations. Agree that automatic doors would be in, and would include the weight of all elements (doors, framework, mechanism which controls movement) Regarding garage doors, we do not fully agree with the scoping guidance provided. If the garage door element is only designed to work in conjunction with the motor supplied we would agree it would be in scope and include the whole weight. If the garage door is capable of being independently opened without the electronic mechanism, then only the weight of the mechanism would be in scope. A roller door and shuttering systems would also be in scope, with the whole weight included. Confirmation from the Agencies requested please.