Regards,
Chris
Regards,
Chris
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Greg Parke
Sent: 26 October 2005 15:23
To: [log in to unmask]
Subject: [LF] WEEE/RoHS implementation questions
Hi All,
I have a few questions regarding the implementation of WEEE/RoHS. The
questions are focused more on the registration side of the issue versus
the
assembly process side. I am finding that the implementation on the
assembly
process side is relatively straightforward, but it is the registrations,
bureaucracy, etc that is more difficult to sort out.
1. It is my understanding that as a producer you only need to
register
in those member states where you have established legal entities. Is
this
correct? Are there any exceptions?
[James, Chris] Correct - exception would be if you belong to a
compliance scheme who would register for you
2. What is the registration process? Is there a common process or
are
they defined by the member states? Is there a place where I can find
out
who the registering authority is?
[James, Chris] Nothing common about it! - Try looking in the Perchards
report on the DTi website. At present you can only register per MS.
3. Do I have to hire a third party in Europe to handle the actual
recycling of equipment? If so, how is the financial side of the process
handled. Is money set aside for each unit sold to insure the producer's
obligation? Could the units be returned to the producer for disposal?
[James, Chris] You might want to look at compliance schemes it could
well be more cost effective than trying to go it alone. It also depends
if your products are business to business or business to household
consumer in some MS - remember all MS can implement differently.
4. If I decide to take the lead solder for use in network
infrastructure exemption (exemption #7) is there a special registration
process? Would the exemption need to be filed for each product sold by
the
company or would it automatically apply to all products?
[James, Chris] No there is no registration process. I would however
strongly advise you formally document any such or similar decision
within your company and keep the record available should any authority
question it.
Thanks in advanced for the help. Also, has anybody out there had any
good
experiences with consultants who have handled the issues above? If so,
can
you send me their names offline?
------------------------------------------------------------------------
----
-------------------------------------
Greg Parke
Senior Manufacturing Engineer
Acme Packet, Inc.
71 Third Avenue
Burlington, MA 01803
781-328-4452 (voice)
781-425-5077 (fax)
603-674-3083 (mobile)
<mailto:[log in to unmask]> [log in to unmask]
<http://www.acmepacket.com> www.acmepacket.com
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