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January 2004

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Subject:
From:
Brian Ellis <[log in to unmask]>
Reply To:
(Leadfree Electronics Assembly Forum)
Date:
Tue, 20 Jan 2004 17:19:29 +0200
Content-Type:
text/plain
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text/plain (115 lines)
Mike

I agree with you, but the European "marketeer" passes the onus up the
chain to the manufacturer. There is then the question of, say, a company
or an individual who imports an item of equipment for their/his own use.
This also must comply, even down to someone who orders a little widget
on the Internet. The question remains open that, if I order such a
widget, how can I prove that it is compliant? Is the supplier's say-so
sufficient? I can think of many companies that I would not trust a
millimetre in this respect (including some manufacturers). In fact, I
can hardly foresee ANY foolproof way of ensuring compliance. If I were
an importer of DVD players made in China, would I have to sacrifice one
per batch for the powers-that-are-to-be to analyse, lest there be a few
milligrams of a forbidden metal hidden in its entrails? Of course, there
will be some arsenic in them, but then that is not a forbidden element,
even though it is far more toxic than lead (Heaven forbid that I appear
cynical!).

Brian

Mike Fenner wrote:
> Unless product falls in to a very narrow class of special exceptions, if
> it is going to be sold/used in Europe then it has to be compliant. So
> question is "wrong way round".
>
> There will probably be lots of focal points on compliance. These will be
> the be the local enforcement agencies but they will only be interested
> in non compliant products and their suppliers, if you see what I mean.
> Onus for compliance is on the person who puts product on the European
> market, not manufacturer who could be anywhere.
>
> Regards
>
> Mike
>
>
>
> -----Original Message-----
> From: Leadfree [mailto:[log in to unmask]] On Behalf Of Lee Whiteman
> Sent: Tuesday, January 20, 2004 2:41 PM
> To: [log in to unmask]
> Subject: [LF] COMPLIANCE QUESTION
>
>
> In conversation with various colleagues and customers, a question has
> come up concerning compliance. How does one know if their hardware has
> to be compliant to the WEEE and RoHS Directives?
>
> In reading them, there are lists of various consumer and commercial
> electronics hardware which must be compliant to the directives. However,
> I've received feedback from various Non-European sources that EU
> customers, whose purchased hardware is not listed in the directives, are
> requiring their Non-European suppliers to become lead free.
>
> Is there a focal point at the EU who can determine if a specific piece
> of electronic hardware must be compliant to the WEEE and RoHS
> Directives?
>
> Just curious.
>
> Thanks for the input.
>
> Lee Whiteman
> Senior Manufacturing Engineer
> American Competitiveness Institute
> E-Mail: [log in to unmask]
> Ph: (610) 362-1200 x208
> Fax: (610) 362-1290
>
>
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