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March 2004

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Subject:
From:
"Kallin, Dan" <[log in to unmask]>
Reply To:
(Leadfree Electronics Assembly Forum)
Date:
Thu, 4 Mar 2004 15:46:19 -0500
Content-Type:
text/plain
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text/plain (48 lines)
> 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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