Your second paragraph would make a good response to the DT
Paul,
Your second paragraph would make a good response to the DTi consultation
to see if we can get a clearer definition although I think you must
separate refurb and upgrade. I think refurb for re-sale is definitely
out but at what level does system expansion or upgrade cease is a good
point.
Regards,
Chris
-----Original Message-----
From: Paul Chinery [mailto:[log in to unmask]]
Sent: 20 October 2004 12:12
To: (Leadfree Electronics Assembly Forum); James, Chris
Subject: RE: [LF] "Put of the Market" Interpretation/ Documentation
Chris
I agree with your previous postings. The blue book considers put on the
market as "product is placed on the Community market when it is made
available for the first time." In theory, a product originally sold
outside
of the EU, which is subsequently refurbished and placed back on to the
EU
market will now fall within the scope of RoHS, as this is the initial
action
of it entering the EU marketplace.
Recycling is positive, but when does a refurbishment cease to be an
upgrade?
Parts that expand the capacity or upgrade equipment that was put on the
market prior to 1st July 2006 are clearly exempt. However, just how
much of
the original equipment must remain for it to be considered an upgrade?
Classic car enthusiasts may be able to offer some guidance.
The blue book considers 'put on the market' to have occurred "when a
product
is transferred from the stage of manufacture with the intention of
distribution or use on the Community market." In simple terms, this
could
be interpreted as once product or finished sub-assemblies COULD be sold,
they are implicated.
Kind regards
Paul
Paul Chinery
Managing Director
Dionics Plc
[log in to unmask] <mailto:[log in to unmask]>
www.dionics.com <http://www.dionics.com>
Phone: +44 (0)24 76 71 33 66
Fax: +44 (0)24 76 71 44 88
Electronica 2004
9 - 12 November
Hall A5
Stand 558
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-----Original Message-----
From: Leadfree [mailto:[log in to unmask]]On Behalf Of James, Chris
Sent: 20 October 2004 11:04
To: [log in to unmask]
Subject: Re: [LF] "Put of the Market" Interpretation/ Documentation
This is exactly why people must respond to the final consultation period
(before 29Oct) to try and get clarification on these (probably
intentionally) vague legalise definitions. Per a previous email my
question to the DTi was:
We would welcome expansion on clause 25 of the RoHS Guidance notes
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.
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of to Paul Taylor
Sent: 20 October 2004 10:49
To: [log in to unmask]
Subject: Re: [LF] "Put of the Market" Interpretation/ Documentation
Dear Dave
this is the 96 trillion dollar question!! reading the EU blue book
phrase
from an earlier email i would have to say that my opinion is that on
the
evening of June 30th 2006 that no more non-compliant parts /units can
leave
the manufacturers door, but so long as they are fit for sale they can be
on
the distributors (either inter company or external) shelves and be sold
son
the 1st July (there will be a lot of trucks rushing around!!).
is that what other OEM suppliers view this to mean ? Also, I guess it
would
be the same for the spares.
regards
Paul
Paul R Taylor
Senior Engineer, Product Supply Group
Pitney Bowes Ltd
email: [log in to unmask]
website: www.pb.com
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