No you can't market new product afte
"finished good" - a product
No you can't market new product after July 2006 which contain the banned
substances, so by extension - for those within the scope of RoHS, no
manufacturer will be wanting to buy lead containing components well
before July 2006.
Regards,
Chris
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Emanuel Zimmermann
Sent: 19 October 2004 08:00
To: [log in to unmask]
Subject: Re: [LF] "Put of the Market" Intrepretation/ Documentation
Hi Forum Members
This is my first post to the forum though I'm watching the threads (BTW
interesting and informative) for a while now. This is may because I've
an
EE background rather than a lawyers education. But this particular
thread
raises a question in me:
What is a "finished good"?
I think that for an IC manufacturer it is the packaged semiconducter.
For our company it is the assembled PCB containing this IC besides other
parts.
For our customer it is his control electronic built around our PCB
together with third party components,
and for his customer it is the molding machine (with which the IC
manufacturer packages his semiconducters) controlled by this electronic.
Now, where has to be drawn the line? Can a product that ones entered the
market, not yet under RoHS, still be used to build another product under
RoHS?
Thanks for your input even if it may be obvious to you. I personally am
going more and more into confusion the more I'm occupied with this LF
initiative.
Emanuel
Leadfree <[log in to unmask]> wrote on 18.10.2004 18:41:28:
>
> 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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