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September 2006

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Subject:
From:
Brian Epstein <[log in to unmask]>
Reply To:
(Leadfree Electronics Assembly Forum)
Date:
Mon, 25 Sep 2006 16:06:30 -0700
Content-Type:
text/plain
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text/plain (206 lines)
I agree.  Ireland seems to have identified WEEE and RoHS as revenue
sources.

Regards,
Brian Epstein
Sr Regulatory Compliance Engineer
Veeco Instruments
ph:  805-967-2700 ext 2315
fx:  805-967-7717
ce:  805-591-9587

-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of John Burke
Sent: Monday, September 25, 2006 9:07 AM
To: [log in to unmask]
Subject: Re: [LF] Is RoHS Compliance not Being Aggressively
Enforced?--from Dr. Ron's Blog

I am not a gambling man, but I predict that the first non-compliance
case
comes up in :

Ireland

John

-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Paul Chinery
Sent: Monday, September 25, 2006 3:14 AM
To: [log in to unmask]
Subject: Re: [LF] Is RoHS Compliance not Being Aggressively
Enforced?--from
Dr. Ron's Blog

A couple of observations regarding Dr. Ron's Blog:

Firstly, customs will have little to do with enforcing RoHS.  Remember,
there are no requirements to provide any compliance information on the
shipping documents and there is no formal marking requirement.
Producers
are only required to provide documentary evidence upon request.  Only
once
product has passed through customs is it technically on the [EU] market.
So
theoretically, even if a non-compliant product was exported to a EU
member
state and seized by customs, it is not yet 'on the market' so no law has
been violated.

Moreover, customs are already fighting a loosing battle against drugs
and
weapons entering our borders.  Do we really want these overstretched
agencies to focus on electronics?  Non-compliant laptops may be
undesirable,
but they don't destroy lives.

Due to the self-declaration method of enforcement, nothing will stop
non-compliant equipment from entering our [EU] borders.  Only once it is
here, will any effort be made to determine compliance.

With regards to enforcement action, I still think we have a couple of
months
to wait.  [July].  The enforcement authorities sample a product.
Documentation provides inconclusive evidence of the compliant status so
full
laboratory analysis of every homogeneous element is performed.  [August]
A
restricted substance is found.  Remedial action is agreed with the
producer.
[November].  Enforcement authorities assess corrective actions and
determine
compliance [December].

So we could be into the New Year before RoHS makes any headline news.

Paul.

Paul Chinery
Managing Director
Dionics Plc
[log in to unmask] <mailto:[log in to unmask]>
www.dionics.com <http://www.dionics.com>
Phone: +44 (0)24 76 71 33 66
Fax: +44 (0)24 76 71 44 88


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-----Original Message-----
From: Leadfree [mailto:[log in to unmask]]On Behalf Of Harvey Miller
Sent: 22 September 2006 23:22
To: [log in to unmask]
Subject: [LF] Is RoHS Compliance not Being Aggressively Enforced?--from
Dr. Ron's Blog


Is RoHS Compliance not Being Aggressively Enforced?

September 18th, 2006

Folks,

July 1, 2006 has come and gone. Most of us expected many problems at the
borders of the EU countries Re customs after this date. All appears
quiet.
I have heard few stories of customs disasters. Since it appeared that <
50% of companies were RoHS compliant, I am wondering what happened. My
guess is that the EU is not ready to perform consistent inspections and
since there is no paperwork requirement (i.e. the act of placing a
product
on the market declares its compliance) product is simply flowing in with
only spotty checks or testing.

Readers, what are you hearing?

Cheers,

Dr. Ron

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