With regard to Dans comment "Does anyone have any insights into how the
DTI might have arrived at their guidance which indicates these are out
of scope? I could find no such exemptions in the directives."
He is right to question it. While items that would be used in vehicles
would fall under ELV (and therefore not RoHS), there is nothing to
suggest items that are part of another piece of equipment (not vehicles)
are outside the scope - that is just an interpretation applied by TAC.
Some people have questioned if TAC has the legal authority to make such
interpretations....
Kay
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of James, Chris
Sent: 08 December 2004 16:19
To: [log in to unmask]
Subject: Re: [LF] scope of directives
Even the examples are poor - plenty of car radios are sold "loose" as
retro fits and plenty end up being used outside of a car environment.
Plenty must end up in the waste stream.
The hard drive example is poor too, yes okay the internal one is exempt
but note the external peripheral one is not BUT what use is hard drive
unless it is configured as part of a system?
No-one is going to give you a definitive decision on this, only the
be-wigged judge the first time this comes to court - you have to make
your own mind up as to what makes the best commercial sense. Not comply
and have to withdraw product, face fines and import bans, or comply for
a modest sum (WEEE sum :) ) and count it as another cost of doing
business.
Agreeably if you can squeak out of WEEE you'll be able to do claim the
same for RoHS but for how long - the stragglers will be dragged in one
way or another.............
Regards,
Chris
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Kallin, Dan
Sent: 08 December 2004 15:46
To: [log in to unmask]
Subject: Re: [LF] scope of directives
Bev, James, et. al.,
I actually don't disagree with the interpretation of the consumer
question. The track which I raised was a little different and based on
DTI's guidance documents for the UKs rules.
The thought process is.....
Since this equipment has no function outside it's installed environment,
like the car radio, and is part of a fixed installation, it should be
exempt.
Does anyone have any insights into how the DTI might have arrived at
their guidance which indicates these are out of scope? I could find no
such exemptions in the directives.
I was under the impression OEM installed vehicle radios were exempt
based on Paragraph 2 of the scope where the ELV is existing waste
management legislation not because they are part of another piece of
equipment.
>>>>>>>>
2. This Directive shall apply without prejudice to Community legislation
on safety and health requirements and specific Community waste
management legislation.
>>>>>>>>
Their guidance does come with the following caveat,
[Please note that the general principle outlined in the following
section has been raised by the UK within the TAC. The Commission has
agreed to seek an opinion from its Legal Services and report back. This
draft Guidance will be amended according to that opinion.]
Has there been any word back from the commission's legal services?
Dan
__________________________________________
Dan Kallin Environmental & Safety Engineer
Bose Corporation Framingham, MA 01701
[log in to unmask]
508-766-7136 (phone)
508-766-7086 (fax)
__________________________________________
-----Original Message-----
From: Bev Christian [mailto:[log in to unmask]]
Sent: Tuesday, December 07, 2004 5:06 PM
To: (Leadfree Electronics Assembly Forum); Kallin, Dan
Subject: RE: [LF] scope of directives
Dan,
As others have said, we hope you get an exemption, but do we really want
to see you try and get it through the courts? My "gut feeling" (I'm no
lawyer), is that the term consumer is not being used in the North
American sense of Joe or Jane average, but ANY purchaser of electronics
- individual, company or entity, other than those stated as having
exemptions. Sorry to rain on your parade. Again, only the opinion of a
chemist. regards, Bev Christian Research in Motion
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]]On Behalf Of Kallin, Dan
Sent: December 7, 2004 4:58 PM
To: [log in to unmask]
Subject: Re: [LF] scope of directives
The DTI guidance on WEEE discusses the following regarding scope. The
question has come up, would sound equipment installed into a fixed
commercial installation by professional installers fit into this
exemption? These are sound systems installed in such venues as stadiums,
auditoriums etc.
Like the equipment below this also has no household market or
application.
Any thoughts?
iii) Items which are electrical and electronic equipment that is part of
another type of equipment or a fixed installation 18. Equipment which is
part of another type of equipment or system is considered to be outside
the scope of the Regulations where it does not have a direct function
outside the other item of equipment (e.g. a car radio). 19. Equipment
may also be part of a fixed installation. A "fixed installation" may be
a combination of several pieces of equipment, systems, products and/or
components (parts) assembled and/or erected by a professional assembler
or installer at a given place to operate together in an expected
environment and to perform a specific task. In such a case, elements of
a system which are not identifiable as electrical and electronic
equipment in their own right or that do not have a direct function away
from the installation are excluded from the scope of the Regulations.
__________________________________________
Dan Kallin Environmental & Safety Engineer
Bose Corporation Framingham, MA 01701
[log in to unmask]
508-766-7136 (phone)
508-766-7086 (fax)
__________________________________________
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]]On Behalf Of Thorup, John
Sent: Monday, December 06, 2004 8:18 PM
To: [log in to unmask]
Subject: [LF] scope of directives
Having just read the directives from beginning to end I have a question
about the scope of the directives. Article 2 paragraph 1 of the RoHS
directive 2002/95/EC states... "this directive shall apply to electrical
and electronic equipment falling under the categories 1, 2, 3, 4, 5, 6,
7 and 10 set out in annex 1A to directive No 2002/96/EC (WEEE) and to
electric light bulbs, and luminaries in households."
In reading WEEE we find these products to be household appliances,
telecom, consumer equipment, lighting, tools, toys and such.
If this is true would not an OEM of niche, high end, professional
broadcast equipment that has absolutely no market or application in any
household be exempt? Thanks, John
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