Comment probably refers specifically to the parts. Technically parts on
their own can be shipped, but these same parts used in new production would
make the EEE noncompliant. Kind of limits the market for noncompliant
parts.
Regards,
Jack
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Roger Stoops
Sent: Friday, September 02, 2005 1:49 PM
To: [log in to unmask]
Subject: Re: [LF] RoHS Scope
And you found this information where? Article 4 specifically states
that EEE (according to the Annex) shall not contain any of the 6 banned
substances above the predetermined limits. Almost sounds as if most
everybody else has mis-interpreted the directive, i.e, going up the
wrong creek.
Regards,
Roger
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Jackie TAYLOR
Sent: Friday, September 02, 2005 11:57 AM
To: [log in to unmask]
Subject: Re: [LF] RoHS Scope
Hi Paul,
I have to disagree. Only "EEE" is obligated to comply. See the
definition of EEE below. Also how can any policing authority know the
intended purpose of parts (paint, nuts, bolts, chips, capacitors, disk
drives, memory sticks etc)? The intended purpose could be for spares or
upgrades.
They could be for network or server. They could be for military or
medical purposes. All the these purposes are exempt. Only the final end
product must comply.
Thanks
Jackie Taylor
Component Engineer
3Dlabs Inc. - A Creative Technology Company
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"James, Chris"
<[log in to unmask]>
Sent by: Leadfree
To
<[log in to unmask]> [log in to unmask]
cc
09/02/2005 09:55 AM
Subject
Re: [LF] RoHS Scope
Please respond to
"(Leadfree Electronics
Assembly Forum)"
<[log in to unmask]>; Please
respond to
"James, Chris"
<[log in to unmask]>
All parts, paint, nuts and bolts in all obligated products must comply
(down to homogeneous levels). So yes if the part goes in an obligated
product then it must comply.
You can still make and sell non RoHS compliant products - you just can't
sell them in the EEC or China from some point next year.
If you are making marine radios that are built into a boat then that
radio does not have to comply because it is part of a ship/boat. I think
the DTi use the analogy of a built in car radio but that falls short
because it would have to comply with ELV.
Regards,
Chris
____________
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Jackie TAYLOR
Sent: 02 September 2005 14:50
To: [log in to unmask]
Subject: [LF] RoHS Scope
Hi All,
I have a question concerning the scope of RoHS. Are computer parts such
as disk drives, power supplies, or video cards etc. required to be RoHS
compliant by July 2006? It appears that only the finished computer
itself must be compliant.
From the DTI Guidance August 2005
"The RoHS Regulations ban the putting on the EU market of new Electrical
and Electronic Equipment
(EEE) containing more than the permitted levels of lead, cadmium,
mercury, hexavalent chromium and both polybrominated biphenyl
(PBB) and polybrominated
diphenyl ether (PBDE) flame retardants from 1 July 2006."
Definition of EEE from the WEEE directive
"(a) ?electrical and electronic equipment? or ?EEE? means equipment
which is dependent on electric currents or electromagnetic fields in
order to work properly and equipment for the generation, transfer and
measurement of such currents and fields falling under the categories set
out in Annex IA and designed for use with a voltage rating not exceeding
1 000 Volt for alternating current and 1 500 Volt for direct current; "
From the DTI Guidance August 2005
"Equipment that is part of another type of equipment or system is
considered to be outside the scope of the Directive where it does not
have a direct function outside the other item of equipment."
Now I realize that the parts must be compliant in order for the complete
system to be compliant however it appears that nothing prevents non
complaint components or parts from be sold.
Thank you
Jackie Taylor
Component Engineer
3Dlabs Inc. - A Creative Technology Company
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