Ah,
But as you state it.
If you use an old memory module, which is not RoHS compliant, in a new
system and place that system on the market after July 1st, then you are
breaking the law and your product should be impounded. The new system is
being put on the market for the first time after July 1st and all
homogeneous materials must be compliant.
Now,
If you took that memory module and used it to upgrade or refurb another old
system then sold that system on the market as a used or refurbed system,
that's OK. You can even sell that non-compliant memory module (or any other
part) as a spare or upgrade for an old system.
Selling non-compliant spares to upgrade or refurb systems put on the market
after July 1st is not allowed. It is allowed for upgrade or refurb of
systems put on the market before July 1st.
Regards,
LS
-----Original Message-----
From: John Burke [mailto:[log in to unmask]]
Sent: Tuesday, August 08, 2006 2:39 PM
To: 'Lester Subrattee'; '(Leadfree Electronics Assembly Forum)'
Subject: RE: Someone in California is doing due diligence on RoHS it seems
Correct and Good point,
If you read the WEEE directive it actually states that:
=========================================================
Where appropriate, priority should be given to the reuse
of WEEE and its components, subassemblies and
consumables. Where reuse is not preferable, all WEEE
collected separately should be sent for recovery, in the
course of which a high level of recycling and recovery
should be achieved. In addition, producers should be
encouraged to integrate recycled material in new equipment.
==========================================================
But the reality is, if I remove a memory module, for example, from a
recycled computer system and re-use it in a new system as "encouraged" to
do, I would be very reluctant to do so due to people running around Europe
with XRF guns at point of entry, unless there were some specific rules laid
down in this area.
Interesting thought though; re-use a memory module in a new system as
encouraged, get all products impounded for 3 months after XRF detection at
point of entry while things are investigated.
Hmmmmmmmmmmm maybe that is where the test case will come from.
I think this will be Lawyer heaven.
John
-----Original Message-----
From: Lester Subrattee [mailto:[log in to unmask]]
Sent: Tuesday, August 08, 2006 10:39 AM
To: (Leadfree Electronics Assembly Forum); John Burke
Subject: RE: Someone in California is doing due diligence on RoHS it seems
Just a comment on your last point.
RoHS directive does allow for the reuse, refurbish and upgrade of old
equipment put on the market before July 1st. As long as it is not resold as
a new product. If the EEE is put on the market as a reused/refurb/upgraded
product the RoHS material restrictions do not apply. Obviously the spares
for old products do not need to comply with the directive as well.
Regards,
LS
-----Original Message-----
From: John Burke [mailto:[log in to unmask]]
Sent: Tuesday, August 08, 2006 12:14 PM
To: [log in to unmask]
Subject: Someone in California is doing due diligence on RoHS it seems
The RoHS machine grinds on. It would seem though that CA is looking a little
harder at the attempts of Assembly Bill AB2202 to map directly the European
legislation.
I just read through the latest bill amendments from yesterday, and all I can
say is that there is light.
Apart from the fact that it will not cut in until 2010, there are some very
interesting variances from the European laws:
Here is an example (1) :
===================================================================
(h) (1) The department shall adopt regulations establishing a
process whereby a manufacturer or distributor of an electronic device
or component may seek an exemption or time extension to a sales
prohibition pursuant to this section upon demonstration to the
department that the device or component meets the criteria developed
pursuant to paragraph (2).
(2) In developing a process, including criteria, for evaluating a
request for exemption and time extension, the department shall
consult with effected stakeholders, including representatives from
the manufacturers, distributors, and environmental groups.
==========================================================================
John's comment:
The above paragraph means that California will consider its own exemption
process, I trust that it will be more logical that the one in place in
Europe and actually allow scientific evidence as input.
Here is another example (2):
===========================================================================
(i) (1) In order to support the refurbishment and reuse of
electronic devices, the department shall adopt regulations allowing
an exemption from any sales prohibition pursuant to this section for
devices that are refurbished, or sold for reuse, or both refurbished
and sold for reuse.
==========================================================================
John's comment:
YAY, someone finally worked it out, RoHS means that all WEEE must be trashed
after July 1st in Europe; this amendment outlined above allows RECYCLING in
CA - what a concept and well done California!!
For those not following the bill progress here is the link to the full
transcript and amendments as of yesterday.
http://tinyurl.com/l8qjj
Kind regards,
John Burke
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