In the UK the National Weights & Measures Laboratory has been charged
with ensuring compliance, hence termed "the Enforcer".
http://www.rohs.gov.uk/Default.aspx
When speaking to Chris Smith who heads the department he has said that
in the early years their job will be educating manufacturers more than
prosecuting them. If you are flagrantly flouting the regs then yes you
will face prosecution, product removal from the market etc. but if you
are making a concerted effort to comply and which is commensurate with
the size of your company, then they will be there to help. This is why
ensuring you document decisions on products you feel do not have to
comply is important as the Enforcer will have to challenge your
rationale.
All the EU Enforcers face much the same issue as the manufacturer in
checking compliance; there is no simple method and a full analysis is
expensive. The Enforcers have a limited budget to firstly purchase the
product to test let alone test it. So if you can demonstrate you have
taken reasonable and practicable steps to ensure compliance you will be
much better placed than the person who hasn't.
Note if you are a UK mfr then the UK Enforcer is the one who will follow
up any referred issues in other members states - same goes for mfrs in
other member states, their home Enforcer deals with the case.
On other matters RoHS & WEEE gathered from the SMART Leadfree event this
week:
(1) TAC meeting 15 Feb 06 agreed 5 new exemptions, details will appear
in DTI unofficial minutes on their website later next week in advance of
actual publication in EU official journal.
(2) EU wide enforcement body network has been set up to normalise
enforcement regimes across all member states and eliminate discrepancies
such as those already come to light and which I pointed out to NWML/Dti.
First meeting of enforcers from 14 of 25 states was held last month.
They will publish guidance document which they are all agreed to be
working to as an aid to industry, but will have no legal basis as the
RoHS directive is the only document that matters.
(3) ERA commissioned to look at category 8/9 exemption from RoHS. Due to
report this Spring, and formal decision this summer.
Regards,
Chris
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Dominic Boudreau
Sent: 17 February 2006 21:42
To: [log in to unmask]
Subject: [LF] non-compliancy consequences
Hi,
I'm working for a little electronic manufacturer and we are working hard
to be RoHS compliant for July 2006. We are working to avoid
cross-contamination with lead but what I'm asking is,
how the European Community will do to be sure that the products sold in
Europe are really lead-free?
Will they have a kind of police who will verify and test the composition
of the products?
If yes, what will be the consequences if they found a banned substance?
Thank you
Dominic
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