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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