Here is what I said in my personal response to the DTI:



 



From: James, Chris 

Sent: 06 October 2004 09:26

To: [log in to unmask]

Subject: RoHS consultation issues



 



Gordon,



We would welcome expansion on clause 25 of the RoHS Guidance notes

especially that shown in bold italics below.



 



Our question is (and that of many other companies spoken to), where is

the exact delineation between "stage of manufacture" and "with intention

of it going to market"?



 



Is it:



a)      When the product transfers from the end of the "production line"

into a "finished goods" area (which may be in the same building or

another building).

or



b)      When it is removed (as a finished product) from the building in

which it was manufactured with the intention of it going to market. E.g.

moving to a shop, distribution centre or similar. i.e. "leaves the

factory gates".

or



c)      When the item changes ownership/title between manufacturer and

customer.



Issue (c) is of concern to those who produce bonded stock for customers

where finished product resides at the customers premises but does not

change title until the product is taken by the customer from the bonded

stock.



 



 



25. A product is placed on the Community market when it is made

available for the



first time. This is considered to take place when a product is

transferred from the



stage of manufacture with the intention of distribution or use on the

Community



market.









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