In response to the Gulf Cooperation Council (GCC) draft RoHS regulation, the EU submitted a few comments about the objectives of the regulation and some differences that were identified between the EU RoHS Directive and the GCC proposal. Bahrain provided a response on behalf of the GCC Standardization Organization (GSO).
The draft GCC regulation specified a requirement for certification by an “Accepted Conformity Assessment Body” but it was unclear how an accepted body is designated.
The GSO responded that the GSO has established a “fully transparent system” for CABs qualification which is already being used for low voltage electronic equipment and toys.
“Relevant information, procedure for notification, and list of notified bodies can be reached at the following link: https://www.gso.org.sa/nb/ “
GSO stated that they will start to accredit Notified Bodies once the RoHS requirements are approved.
Self-Declaration vs. Certification
The EU suggested that the EU RoHS approach of manufacturer self assessment and declaration may be “less trade restrictive” than pre-market certification.
The GSO responded that they are seeking the simplest approach but that their market surveillance system is still weak, so it is too early to rely on a system based on self-declaration.
“… GSO needs first to strengthen the Market Surveillance in Member States, to establish a legal framework for producers liability and to encourage Consumer Protection Associations that contribute significantly to Market Surveillance.”
Exclusions for spare parts and other equipment
The EU noted that the draft does not include the general exclusion for spare parts for the repair and upgrade of older products. The GSO responded that it will consider adding such a provision for spare parts to align with EU RoHS.
Alignment with EU RoHS exemptions
There are differences between the latest EU RoHS exemptions and the draft GCC RoHS. The GSO agreed to align the exemptions with EU RoHS Annex III and IV as last updated on “18 May 2018” and to include time limits on the exemptions.
Duplicate declarations by manufacturer and importer
The EU raised a concern that the requirement for similar declarations from both the manufacturer and the importer was redundant and inefficient. The GSO acknowledged that this issue has been previously raised on other regulations and the GSO is seeking with GCC member states to find a way to simplify this requirement.
Harmonized Implementation of requirements
The EU raised a desire for harmonized implementation of GCC RoHS across the GSO and its member countries. The GSO responded:
“This is the central mission of GSO, which commit and push towards a uniform implementation of GSO TRs,… “
Impact on EEE Manufacturers
The GSO commitment to align with EU RoHS on most of the technical requirements (except self-declaration) and to harmonize implementation across the GCC member states will be welcome to EEE manufacturers. However, it appears that the certification requirement for RoHS compliance is likely to remain.
The agreement to add time limits on the exemptions to align with EU RoHS could create some challenges. History with other RoHS regulations has shown that most countries can’t maintain the exemptions as quickly as the European Commission, causing misalignment and potentially leading to old exemptions expiring without new exemptions being implemented in time. The upcoming inclusion of RoHS exemptions in the IEC62474 International standard could help regulators outside of the EU by enabling them to directly reference an International Recognized list that is maintained as up to date.