For purposes of Red List compliance, components meeting the definition of a small electrical component may be present in a product without CAS Registry Number reporting through use of exception RL-002b Small Electrical Components. A Small Electrical Component (SEC) is defined as any discrete, assembled component with any number of terminals, leads, or electromechanical components that is shipped as a unit from a supplier to the final product manufacturer. These terminals, leads and electromechanical components can connect to create an electronic circuit to perform a particular function, or be integrated within a package, and may be considered part of the main SEC. To be considered an SEC, a component must be fully sealed and enclosed within the final product. SECs may be active, passive or electromechanical.
Complex electrical or data products that are made up entirely of SECs are also considered small electrical components. Large electrical equipment, such as a photovoltaic (PV) panel, may however be only partially composed of small electrical components.
When a number of small electrical components are within a housing, the equipment housing and other major components, such as glass, are subject to disclosure and Red List chemical compliance regardless of whether they are a large or small piece of equipment.
Associated Materials Included in Small Electrical Components
The following section identifies materials associated with Small Electrical Components that are considered part of an SEC:
- Wiring that is rated 250V or less working voltage, inclusive of terminals, leads, electromechanical components and associated jacketing, if included with the component as supplied to the final product manufacturer (i.e., not manufacturer-installed)
- Supplier modifications (i.e. not manufacturer-implemented) to wiring such as pigtails
Associated Materials Not Included in Small Electrical Components
The following section identifies materials associated with Small Electrical Components that are not considered SEC and which must be inventoried and screened per typical Red List requirements:
- Casing and housing materials for the SEC, including but not limited to enclosures for large equipment containing multiple SEC’s and enclosures for equipment such as electrical panel boards, fire alarm controls, and other electronics,
- Wiring that is rated greater than 250V working voltage, inclusive of terminals, leads, electromechanical components and associated jacketing
- Any wiring used to distribute building power or communications/data
- Any other manufacturer-installed materials, or ingredients, or modifications to SECs
- Any electrical components that are not compliant to EU RoHS 3 (Directive 2015/863)
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