14-1124 v2.X I10E2 vs I10 E3

Question:

I am looking to vet the Cadet CEC163TTW Energy Plus Wall Fan Forced Heater (see link - https://greenhammer.box.com/s/oz9urhswzelzg4oii1uc). After communicating with the manufacturer, they were able to provide me with RoHS compliance (see attached); however, when I pushed for Red List Compliance they were unable to comply based on the minimal presence of Red List materials.Yet, I still believe that this product could be excepted via I10-E2 5/2013 Small Electrical Components due to it's RoHS compliance and not need to be tracked for Red Listed materials. Moreover, the product could also satisfy I10-E3 4/2010 Small Mechanical Components because it is part of a larger complex mechanical system, where the housing of that system should then be tracked.Am I correct to apply either of these two exceptions to this product? https://ilbi.org/action/community/dialogue/materials/red- list/99/552383972/30908913/Rohs-Compliance-Cadet-2.pdf

Answer:

Exception I10-E2 5/2013 is more applicable to this product since the small components with Red List ingredients seem to be primarily electrical. Note that under either exception, the project team must still gather supporting data for the equipment housing and other major components as well as send an advocacy letter to the manufacturer requiring elimination of Red List ingredients.


Post ID 2039

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