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October 2005

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Subject:
From:
"James, Chris" <[log in to unmask]>
Reply To:
(Leadfree Electronics Assembly Forum)
Date:
Wed, 26 Oct 2005 17:15:45 +0100
Content-Type:
text/plain
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text/plain (332 lines)
If you put http://www.stiftung-ear.de/ into google and search and then
hit the translate button next to the resultant hit you get a fair
translation of all the html pages from all the links on the main
page........ clever stuff this internet

Regards,
Chris
 

-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Greg Parke
Sent: 26 October 2005 16:47
To: [log in to unmask]
Subject: Re: [LF] WEEE/RoHS implementation questions

I had the same take on Germany as well.  In our case it didn't matter
since
we have a legal entity there.  It was also my impression that you had to
register by November 24, 2005.  Unfortunately the website of the
registering
authority (www.stiftung-ear.de) is mostly in German so it wasn't all
that
clear.

-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Nic Bowker
Sent: Wednesday, October 26, 2005 11:28 AM
To: [log in to unmask]
Subject: Re: [LF] WEEE/RoHS implementation questions

Just to throw a spanner in the works....I was talking to someone at
Valpak
(a compliance scheme in the UK) who was convinced that even if you did
not
have a legal entity in Germany, under their WEEE Regs you'd have to
register.

Still seems unlikely to me, but there you go.

Anyone care to comment?

Nic Bowker
Technical Resources Adviser
PLASA Ltd.
38 St Leonards Road, Eastbourne, East Sussex, BN21 3UT, UK.
Tel:  +44 (0)1323 410335 : Fax: +44 (0)1323 646905
Email: [log in to unmask] : Website: www.plasa.org

Join one of the largest trade communities in the industry.
www.plasa.org


-----Original Message-----
From: James, Chris [mailto:[log in to unmask]]
Sent: 26 October 2005 15:53
To: [log in to unmask]
Subject: Re: [LF] WEEE/RoHS implementation questions


Regards,

Chris







Regards,

Chris





-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Greg Parke
Sent: 26 October 2005 15:23
To: [log in to unmask]
Subject: [LF] WEEE/RoHS implementation questions



Hi All,







I have a few questions regarding the implementation of WEEE/RoHS.  The

questions are focused more on the registration side of the issue versus
the

assembly process side.  I am finding that the implementation on the
assembly

process side is relatively straightforward, but it is the registrations,

bureaucracy, etc that is more difficult to sort out.







1.      It is my understanding that as a producer you only need to
register

in those member states where you have established legal entities.  Is
this

correct?  Are there any exceptions?

[James, Chris] Correct - exception would be if you belong to a
compliance scheme who would register for you

2.      What is the registration process?  Is there a common process or
are

they defined by the member states?  Is there a place where I can find
out

who the registering authority is?

[James, Chris] Nothing common about it! - Try looking in the Perchards
report on the DTi website. At present you can only register per MS.

3.      Do I have to hire a third party in Europe to handle the actual

recycling of equipment?  If so, how is the financial side of the process

handled.  Is money set aside for each unit sold to insure the producer's

obligation?  Could the units be returned to the producer for disposal?

[James, Chris] You might want to look at compliance schemes it could
well be more cost effective than trying to go it alone. It also depends
if your products are business to business or business to household
consumer in some MS - remember all MS can implement differently.

4.      If I decide to take the lead solder for use in network

infrastructure exemption (exemption #7) is there a special registration

process?  Would the exemption need to be filed for each product sold by
the

company or would it automatically apply to all products?

[James, Chris] No there is no registration process. I would however
strongly advise you formally document any such or similar decision
within your company and keep the record available should any authority
question it.







Thanks in advanced for the help.  Also, has anybody out there had any
good

experiences with consultants who have handled the issues above?  If so,
can

you send me their names offline?







------------------------------------------------------------------------
----

-------------------------------------



Greg Parke



Senior Manufacturing Engineer

Acme Packet, Inc.



71 Third Avenue



Burlington, MA 01803



781-328-4452 (voice)



781-425-5077 (fax)



603-674-3083 (mobile)



 <mailto:[log in to unmask]> [log in to unmask]



 <http://www.acmepacket.com> www.acmepacket.com



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