Hi Geoff, Chris, Scott IPC LF Listservers,

Chris already answered this as did Scott in an example, so hopefully I am
adding only a bit.

<Can anyone tell me categorically whether existing product already on
the EU market must comply with ROHS by July 2006, or whether the ROHS
Directive only applies to new product placed for the first time on the
EU market?>

If the product is already on the market it doesn't have to be returned
to the "producer" in that member state.

<===== Scott's note ====>
<I would add that the above is suggested to apply to brand new product, not
used or re-furbished. That is only my reading between the lines and not
anything the various documents would indicate. One could argue the re-
furbished part either way I suppose. I also realize that any product sold
to an end user prior to 1 July 2006 does not need to be RoHS compliant and
can be repaired with non-compliant parts, etc.>


re-furbished must be re-used, repaired etc.
 and not
re-built as a new product for sale by a "producer"

RoHS Article:2 (3) is the only current caveat in the Directive.
You could put these sub-parts that are RoHS non compliant on the
market after July 2006 to make repairs.


Now just one side point, off your original topic, yet maybe important in
certain cases. When the UK / DTI did it's consultation there was an issue
of what to do with all the pre RoHS parts and components called LTB, Last
Time Buy, or Life Time Buy. I don't know the status of this exemption
proposal yet it was a good idea in line with sound thinking.


Yours in Engineering, Dave
Y i Engr, MA/NY DDave

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