Gary,
Your fears are probably well-founded, although [disclaimer] I cannot say for an absolute certainty some or all of your products may or may not be required to be RoHS/WEEE compliant. We make products that also mount on agricultural equipment, and after our own investigation considered our products *not* to be under category 8 or 9 (reproduced below from 2002/96/EC, Annex 1). Your equipment for ag vehicles, as well as equipment we manufacture, is probably aftermarket equipment, not something required to make the vehicle work, like an ignition module or electronic transmission control or such, and therefore considered a part of the vehicle.
8. Medical devices (with the exception of all implanted and infected products)
Radiotherapy equipment
Cardiology
Dialysis
Pulmonary ventilators
Nuclear medicine
Laboratory equipment for in-vitro diagnosis
Analysers
Freezers
Fertilization tests
Other appliances for detecting, preventing, monitoring, treating, alleviating illness, injury or disability
9. Monitoring and control instruments
Smoke detector
Heating regulators
Thermostats
Measuring,weighing or adjusting appliances for household or as laboratory equipment
Other monitoring and control instruments used in industrial installations (e.g. in control panels)
Items for use in a laboratory are exempted as well as industrial controls, items that more than likely will be used for many years and are not as quick to find their way into the waste stream, so some of your products may be exempt.
Here is a link to 70/155/EEC:
http://europa.eu.int/smartapi/cgi/sga_doc?smartapi!celexapi!prod!CELEXnumdoc&lg=EN&numdoc=31970L0156&model=guichett
Maybe some else on the forum can direct you to a person or company that could help you categorize your products.
Best Regards,
Roger
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]]On Behalf Of Gary Camac
Sent: Monday, November 22, 2004 3:23 PM
To: [log in to unmask]
Subject: [LF] Another question on exemption
Good day everyone,
We have been having discussions at our facility concerning the RoHS
status of our products. We make agricultural monitors and controllers
that are ultimately mounted to tractors, combines, planters, and hay
harvesters. We also manufacture analytical instrumentation ranging from
hand held moisture testers, that a farmer would use in the field, to
laboratory units used for grain analysis.
Management feels that our products are exempt because they are category
9, per 2002/95/EC, article 2, para. 1. I fear this may be a generous
interpretation that could ultimately be costly.
How can I determine the status of our products?
I was also trying to determine if agricultural equipment was covered by
2000/53/EC (on end-of life vehicles). I cannot seem to run down a copy
of 70/156/EEC, which is needed to determine the definition of 'vehicle'.
Does anyone know where I could obtain one?
Thanks for any help,
Gary Camac
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