Fern
Be that as it may, TBBPA is already being targeted for the next phase of
flame-retardant banning. We shall have to face up to this. It is used in
polycarbonates as well as epoxies, so the plastic cases on our monitors
and many other devices will also be on their way out. I guestimate that
our dearly beloved authorities may give us up to about 2010 for
implementation. The bromine industry is tearing its hair out.
Brian
Fern Abrams wrote:
> Joe
>
> Yes and Mostly no. Right now CA is the only state with a ROHS type law.
> ME is currently legislating a bill that would ban certain BFRs
> (hopefully only those banned in CA and the EU). Many US states are
> contemplating WEEE type legislation.
>
> Fern Abrams
> Director of Environmental Policy
> IPC
> 1333 H St NW
> 11th Floor, West Tower
> Washington, DC 20005
> 202-962-0460
> fax 202-962-0464
> www.ipc.org
>
>
> -----Original Message-----
> From: Kane, Joseph E [mailto:[log in to unmask]]
> Sent: Tuesday, April 06, 2004 10:08 AM
> To: [log in to unmask]
> Subject: Re: [LF] FW: Transition of WEEE and RoHS
>
>
> "More and more US states are coming on board with similar
> legislation..."
>
> CRT recycling aside, is this true?
>
> -Joe
>
> -----Original Message-----
> From: James, Chris [mailto:[log in to unmask]]
> Sent: Tuesday, April 06, 2004 4:09 AM
> To: [log in to unmask]
> Subject: Re: [LF] FW: Transition of WEEE and RoHS
>
>
> Dan,
> If you are exporting electrical an electronic equipment to the EU then
> you should be aware of the Electromagnetic Compatibility (EMC) Directive
> and Low Voltage (LVD) directive as your poducts should almost certainly
> be CE marked!
>
> The Electromagnetic Compatibility (EMC) Directive Council Directive of 3
> May 1989 covers the electromagnetic emissions from equipment and the
> immunity of that equipment from incoming electromagnetic signals. Since
> 1 January 1996 most electrical and electronic products must be so
> constructed that they do not cause excessive electromagnetic
> interference and are not unduly affected by such electromagnetic
> interference and be CE marked.
>
> As with RoHS the directive could not be grandfathered, i.e. from 1/1/96
> all product within the scope had to comply.
>
> Within the community it was informally acknowledged there would be a
> grey area around the date of implementation and that so long as
> companies demonstrated due diligence in attempting to meet (rather than
> flout) the directive then it would be unlikely that any action would be
> taken. I think it would be fair to say that common sense prevailed and
> it was some months before any prosecutions were brought to court against
> companies who made no attempt to comply.
>
> The "lead" police are not going to be out there with their lead sniffer
> dogs looking for product on 1st July 2006 - some countries may be more
> vigourous than others in their aplication of the law but then everyone
> has had long enough to get to grips with the situation - the time line
> is drawn - - use your common sense how you cross it. And remember it is
> not just lead that the RoHS directive covers. In addition you should be
> aware of the WEEE directive which applies from Aug 2005.
>
> Finally this is not just an EU situation. More and more US states are
> coming on board with similar legislation, China is adopting pretty much
> the EU RoHS directive, Japan already has legislation covering certain
> electrical products..........
>
>
>
>
> Regards,
>
> Chris
> _______________________________________________
>
>
> Chris James
> Engineering Services Manager
> Dolby Laboratories, Inc. (UK)
> Direct: 01793 842136
>
>
> -----Original Message-----
> From: Leadfree [mailto:[log in to unmask]] On Behalf Of Kallin, Dan
> Sent: 05 April 2004 21:50
> To: [log in to unmask]
> Subject: Re: [LF] FW: Transition of WEEE and RoHS
>
>
> Hello all and thank you for the responses.
>
> It seems based on reading the available guidance, that for an overseas
> manufacturer, customs is the point that it is "put on the market" rather
> than the manufacturer gate or store front.
>
> It seems therefore that my original hypothetical scenario is valid:
>
>
>>>>An extreme hypothetical example may be...
>>>>You have two pallets of radios waiting to clear customs (i.e. 'put on
>>>>the market'). One clears on Friday June 30 2006. The other does not
>
>
>>>>clear until Monday July 3. The products on the first pallet can have
>>>>lead in them. The products on the second cannot.
>>>>
>
>
> Chris, can you comment on the implementation of the EMC directive some
> more? I am not familiar with it.
>
> Assuming it said products must do X by Y date, It seems highly likely
> that there would be products "on the market" but in a retailers
> inventory and not yet sold on Y date minus a day. These are the
> products on the first pallet in my scenario.
>
> Were retailers required to clear their shelves at midnight?
>
> Nick, you mentioned four ways to manage non-compliant product.
> 1) Make sure you don't have any left in your supply pipeline by the time
> 1 July 2006 comes around.
>
> I agree that is the one to work toward, but in reality, It is certainly
> feasible that a product can sit in a wholesaler's or retailer's
> inventory for a few months. I see nothing to indicate these products are
> illegal. Am I missing something?
>
> BTW, grandfathered means exempted. It must be a US term. Sorry for the
> confusion.
>
> Thanks again for your insights
> Dan
>
>
>
> -----Original Message-----
> From: Brian Ellis [mailto:[log in to unmask]]
> Sent: Monday, April 05, 2004 11:40 AM
> To: [log in to unmask]
> Subject: Re: [LF] FW: Transition of WEEE and RoHS
>
>
> Nick
>
> I hope the judges can also distinguish EC legal speak from the
> dictionary definition. Even the OED is rather vague about the definition
> and it could certainly be interpreted badly. IMHO the interpretation you
> quoted is very ambiguous and consequently a good lawyer could drive a
> horse and cart through it. The word "product" should not have been used.
>
> Hee-hee :-)
>
> Brian
>
> Jolly Nick (Mr N) wrote:
>
>
>>Brian
>>
>>Chris is right though I too, when I first came across the term,
>>thought product meant product line but was corrected by our legal
>>people.
>>
>>Product in EC speak is each individual piece of equipment.
>>
>>Regards
>>
>>Nick
>>
>>
>>
>>-----Original Message-----
>>From: James, Chris [mailto:[log in to unmask]]
>>Sent: 05 April 2004 15:42
>>To: [log in to unmask]
>>Subject: Re: [LF] FW: Transition of WEEE and RoHS
>>
>>
>>No that is not correct. The RoHS is applied just the same as the EMC
>>directive. So for the RoHS that means the sale of products as defined
>>by
>
> the
>
>>directive may not contain lead (or other perscribed substances) after
>>July 2006 irrespective of how long they may have already been sold
>>for.
>>
>>Regards,
>>
>>Chris
>>_______________________________________________
>>
>>
>>Chris James
>>Engineering Services Manager
>>Dolby Laboratories, Inc. (UK)
>>Direct: 01793 842136
>>
>>
>>-----Original Message-----
>>From: Leadfree [mailto:[log in to unmask]] On Behalf Of Brian Ellis
>>Sent: 05 April 2004 15:30
>>To: [log in to unmask]
>>Subject: Re: [LF] FW: Transition of WEEE and RoHS
>>
>>
>>Nick
>>
>>Are you sure you really mean "placing on the market is the initial
>>action
>
> of
>
>>making a product available for the first time on the Community market,
>
> with
>
>>a view to distribution or use in the Community."? If I had a factory
>
> making,
>
>>say, a DVD player model XYZ1234 and I started to sell that product in
>>the
>
> EU
>
>>before 1 July 2006, I could continue to manufacture and sell it with
>>lead-bearing solder, until 2020 or later, according to your
>
> interpretation,
>
>>assuming it was so good that it remained marketable for 14+ years :-)
>>
>>What a loophole !!!
>>
>>Brian
>>
>>[log in to unmask] wrote:
>>
>>
>>
>>>Pascal
>>>
>>>You are quoting from the responses to DTI's first consultation. The
>>>second paper,
>>>
>>>http://www.dti.gov.uk/sustainability/weee/consultationpartiii.pdf
>>>
>>>part of which I have pasted below, is based on further input from the
>>>European Commission. Most respondents agreed with the proposal and we
>
>
>>>will be using this definition.
>>>
>>>I'm no legal expert but believe this means when it is first offered
>>>for sale rather than when it left the factory gates.
>>>
>>>
>>>Part III - The RoHS Directive
>>>Issue 2 - Definition of "Put on the Market"
>>>11. Article 4 of the RoHS Directive states that "Member States shall
>>>ensure that, from 1 July 2006, new electrical and electronic equipment
>
>
>>>put on the market does not contain" any of the restricted substances.
>>>Considerable concern has been expressed about the term "put on the
>>>market" and a number of alternative interpretations have been put
>>>forward. The Government proposes to: . transpose the term "put on the
>>>market" in the implementing Regulations taking into account the
>>>context in which it appears in Article 4 of the Directive; and . make
>>>reference to the interpretation offered by the European Commission in
>>>its Guide to the implementation of Directives based on the New
>>>Approach and the Global Approach in the guidance that will be issued
>>>to assist companies to comply with the requirements of the Directive.
>>>That interpretation is that "placing on the market is the initial
>>>action of making a product available for the first time on the
>>>Community market, with a view to distribution or use in the
>>>Community." Question 2
>>>Do you agree with the Government's intended approach in
>>>relation to the term "put on the market"?
>>>
>>>
>>>Regards
>>>
>>>Nick
>>>
>>>From: Nick Jolly, Dept. of Trade & Industry
>>> Electronics Unit
>>>E-mail: [log in to unmask]
>>>Tel: +44 (0)20 7215 1331
>>>Fax: +44 (0)20 7215 1966
>>>Mobile: 0787 640 7444
>>>Snail: Bay 254
>>> 151 Buckingham Palace Road
>>> London SW1W 9SS
>>>
>>>
>>>-----Original Message-----
>>>From: Pascal Guiheneuf [mailto:[log in to unmask]]
>>>Sent: 05 March 2004 09:01
>>>To: [log in to unmask]
>>>Subject: Re: [LF] FW: Transition of WEEE and RoHS
>>>
>>>
>>>Hello, Dan,
>>>
>>>My feeling is that your concern shall be addressed by Member States
>>>for the transposition, before August 13th 2004. You are looking for a
>>>legal topics.
>>>
>>>You can have a look at
>>>http://www.dti.gov.uk/sustainability/weee/index.htm#Consultation_on_Go
>>>vernme
>>>nt_implementation where you will see the item addressed by UK
>>>government, with suggestions for the decree. They questionned people
>>>on them.
>>>
>>>ROHS DIRECTIVE QUESTION 1
>>>Concern has been expressed about the term 'put on the market'. Does
>>>this mean equipment manufactured after 30 June 2006, all equipment
>>>leaving the manufacturer's premises after this date or all equipment
>>>on sale to the final user after this date? The Government would
>>>welcome your views on what you consider to be the most practicable and
>
>
>>>unambiguous interpretation. Our initial view is that it should apply
>>>to goods leaving the factory gate (or, where manufacture takes place
>>>outside the single market, on entry to the EU).
>>>
>>>Results :
>>>
>>>Meaning for EU Countries.
>>>1. No View (26%)
>>>2. Manufactured After 30th June
>>>2006 (14%)
>>>3. Leaving Factory Gate (45%)
>>>4. On Sale to Final User (1%)
>>>5. Other (14%)
>>>
>>>Meaning for non-EU Countries.
>>>6. No View (39%)
>>>7. Entry to the EU (57%)
>>>8. Other for Outside EU (4%)
>>>
>>>Alternative suggested definitions, for 'put on the market' within the
>>>EU,
>>>included:
>>>* 'When it is introduced for the first time into any part of the
>>>distribution chain in the EU.'
>>>* 'Date of manufacture as identified on the rating plate.'
>>>* 'The definition [...] should be the same as that defined in Clause
>>>2.3
>>
>>of
>>
>>
>>>'Guide to
>>>the implementation of Directives based on the New Approach and the
>>>Global Approach''. Alternative suggested definitions, for 'put on the
>>>market' outside the EU,
>>>included:
>>>* 'goods received by the importer after 30 June 2006.'
>>>* 'should apply to goods leaving the factory gate even the
>>>manufacturer is located outside the single market.'
>>>
>>>Pascal GUIHENEUF
>>>Nortel France
>>>
>>>-----Original Message-----
>>>From: Kallin, Dan [mailto:[log in to unmask]]
>>>Sent: jeudi 4 mars 2004 21:46
>>>To: [log in to unmask]
>>>Subject: [LF] FW: Transition of WEEE and RoHS
>>>
>>>
>>>
>>>
>>>
>>>>I have a WEEE / RoHS implementation question(s) for the group . I
>>>>was asked,
>>>>
>>>>..... regarding the phase-in of this policy. Will current products
>
> be
>
>>>>grandfathered even if they are physically manufactured after that
>>>>date (and for how long) or does the grandfathering only apply to
>>>>inventory that is already produced and stored before the start date
>>>>of the new regulation?
>>>>
>>>>My understanding is as follows:
>>>>* the "phase in" period ENDS on July 1, 2006
>>>>* The directives are applied to individual products, not product
>>>>lines.
>>>>* A product is placed on the market when it leaves an EU
>
> manufacturer
>
>>>>or is cleared through an EU Country customs for distribution in an EU
>
>
>>>>state.
>>>>
>>>>An extreme hypothetical example may be...
>>>>You have two pallets of radios waiting to clear customs (i.e. 'put on
>
>
>>>>the market'). One clears on Friday June 30 2006. The other does not
>
>
>>>>clear until Monday July 3. The products on the first pallet can have
>>>>lead in them. The products on the second cannot.
>>>>
>>>>My questions are:
>>>>1 - Is my understanding correct?
>>>>
>>>>2 - Does anyone have any idea how existing, non-compliant inventory
>>>>will need to be managed?
>>>>
>>>>Thanks
>>>>__________________________________________
>>>>Dan Kallin Environmental & Safety Engineer
>>>> Bose Corporation Framingham, MA 01701
>>>> [log in to unmask]
>>>> 508-766-7136 (phone)
>>>> 508-766-7086 (fax)
>>>>__________________________________________
>>>>
>>>
>
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